Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 212

                                                -283-                                                   
            Partnership which in turn KWJ Partnership used to make so-called                            
            consulting payments to Ballard’s and Lisle’s adult children                                 
            during the period 1983 to 1989.  Lisle was aware of and                                     
            acquiesced in these payments, and he was aware that the children                            
            were not providing any meaningful services in exchange for the                              
            payments.                                                                                   
                  We conclude Lisle owned Carlco and all of its assets, and                             
            Lisle used Carlco as a conduit for receiving his share of the                               
            payments from The Five.                                                                     
                  (ii).  TMT                                                                            
                  During 1984, TMT purportedly made loans to Ballard,                                   
            Seabright Trust, and Seabright Corp.120  By 1989, TMT’s                                     
            outstanding loans to Seabright Trust and Seabright Corp. totaled                            
            $135,155 and $41,520, respectively.  The record does not include                            
            any promissory notes issued in connection with the loans to                                 
            Seabright Trust or Seabright Corp.  There is no evidence that                               
            either Seabright Trust or Seabright Corp. paid interest on the                              
            loans from TMT.  As of the time of trial, the loans had not been                            
            repaid.                                                                                     
                  From 1984 through 1989, TMT lent $146,943 and $160,000 to                             
            Claude and Mary Ballard, respectively.  Although Ballard                                    

                  120  Ballard believed Seabright Trust was an entity used to                           
            make tax-sheltered investments.  Seabright Corp., which owned a                             
            farm in Arkansas, was owned by the Mary Family Trust, a trust for                           
            the benefit of Ballard’s wife and daughters.                                                






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