Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 211

                                                -282-                                                   
            nothing to shield Ballard and Lisle from oversight or second-                               
            guessing by IRA’s officers.                                                                 
                  In sum, IRA’s transfers to Carlco, TMT, and BWK represented                           
            Lisle’s, Ballard’s, and Kanter’s shares of the payments derived                             
            (and to be derived) from transactions with The Five.  Further,                              
            Carlco, TMT, and BWK were removed from IRA’s consolidated group                             
            to reflect the reality that those corporations were owned and                               
            controlled by Lisle, Ballard, and Kanter, respectively, and they                            
            would each be responsible for their own taxes going forward.                                
                  b.  Use and Enjoyment of Carlco’s, TMT’s, and BWK’s Assets                            
                  We do not credit Kanter’s explanations for the transfers to                           
            Carlco, TMT, and BWK, and for the removal of those entities from                            
            IRA’s consolidated group.  The record shows that Lisle, Ballard,                            
            and Kanter had unrestricted use and enjoyment of Carlco’s, TMT’s,                           
            and BWK’s assets, respectively.                                                             
                  (i).  Carlco                                                                          
                  In April 1985, Lisle wrote a check for $3,000 against funds                           
            in the Connecticut National Bank account to repay a loan that                               
            TACI made to RWL Cinema Trust (one of Lisle’s grantor trusts).                              
            The memo section of this check stated:  “Payment on Loan”.  In                              
            short, Lisle used Carlco’s funds as his own to pay a debt of his                            
            grantor trust.                                                                              
                  In addition, Carlco owned a 45-percent partnership interest                           
            in KWJ Partnership.  IRA made substantial loans to KWJ                                      






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