-276-                                                   
            conduit to transfer to Lisle at least a portion of his share of                             
            payments remitted to THC.117                                                                
                  b.  THC Transfers to Kanter                                                           
                  During the period 1983 to 1984, THC transferred substantial                           
            sums of money into TACI accounts, and TACI transferred smaller                              
            amounts back to THC.  During this same period, Kanter received                              
            substantial loans from TACI, and many of these loans, totaling                              
            approximately $1.3 million, had not been repaid when TACI filed                             
            for bankruptcy in early 1988.  There is no evidence that Kanter                             
            ever paid any principal or interest on these loans.118  Kanter                              
            arranged for transfers from THC to TACI and from TACI to himself                            
            with no intention of repaying TACI or THC.                                                  
                  F.  Kanter-Related Entities Were Shams                                                
                  1.  IRA and THC                                                                       
                  IRA, THC, and their subsidiaries served no legitimate                                 
            business purpose with regard to the transactions at issue in                                
            these cases.  The entities did not have employees and generally                             
            only used the services of bookkeepers and administrators to                                 
            record transactions, receive and disburse funds, and handle                                 
                  117  As previously noted, an earlier ruling in these cases                            
            bars an additional allocation of income from the Travelers                                  
            transactions to Lisle.  Because we are convinced that Lisle                                 
            received at least $682,250 from the Travelers transactions, we                              
            shall take this factor into account and reduce the allocation to                            
            Kanter by a like amount.                                                                    
                  118  Gallenberger believed the TACI bank records that would                           
            have clarified many of the questions surrounding Kanter’s loans                             
            were last in Kanter’s possession.                                                           
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