-295-
with this explanation, Ballard and Lisle, as TMT’s and Carlco’s
managers, were fully cognizant of the payments that KWJ
Partnership was making to their children. Kanter’s letters
contradict this scenario, are not credible, and represent an
11th-hour attempt by Kanter to recharacterize the payments to
Ballard’s and Lisle’s children as a clerical or administrative
error.
Kanter’s letters were also inconsistent with the record in
these cases to the extent Kanter suggested that no one was
managing IRA during the latter half of the 1980s. Although
Kanter’s letters rang true in the sense that Freeman was not
managing IRA (in fact, Freeman never managed IRA), the record in
these cases amply demonstrates that someone was in firm control
of IRA’s affairs. Recall, for example, that in 1987 IRA (1)
engaged in a complex transfer of notes with IFI and then sold 10
of those notes for $1 each to MAF, and (2) discounted and then
wrote off as bad debts notes due from Ballard and Lisle
individually. As had been the case all along, the person firmly
in charge of IRA’s affairs was Kanter.
H. Conclusion and Schedule of Income Adjustments
As previously discussed, we have weighed the recommended
findings of fact and credibility determinations set forth in the
STJ report against the entire record in these cases. On the
basis of our review, with particular emphasis on the additional
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