-293-
were the Bea Ritch Trusts, which owned IRA (and purportedly TMT),
strains credulity.
In August 1989, Ballard submitted to the Compliance
Department at Goldman Sachs a Request for Approval of Outside
Business Activities and/or Private Investments Form. In response
to a direction to provide a “Complete description of the
investment or business affiliation. What is it and who else is
involved in it as principals? Does it involve a public or
private company?”, Ballard answered, in part: “Farmland--Have
been buying and selling for years.” If Ballard was managing TMT
for IRA as he and Kanter contend, Ballard would have been
required to disclose to Goldman Sachs that TMT and/or IRA were
the principal owners of the farmland that Ballard was buying and
selling.
The record also shows that Ballard did disclose to Goldman
Sachs that he served as the director of an organization called
ICM Property Investors. His involvement in this organization was
through a “close friend” who controlled the organization.
Ballard never submitted such a form to Goldman Sachs with respect
to TMT because Ballard owned TMT.
7. Kanter’s Letters to the Ballard and Lisle Children
In early February 1990, after the IRS began examining
Ballard’s, Kanter’s, and Lisle’s tax returns for the years at
issue, Kanter sent letters to Ballard’s and Lisle’s children
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