-303-
E. Commingling of Kanter’s and Ballard’s Income With Funds
Belonging to Others
Kanter and Ballard commingled their income with funds
belonging to others. Kanter directed and oversaw the commingling
of the moneys. Commingling of the income in TACI’s and PSAC’s
accounts with other unrelated income was designed to conceal the
nature of the income and the identities of the true earners of
the income. Kanter plainly attempted to disguise the nature and
source of the income by channeling the moneys through conduit
entities in an array of transfers over a period of many years.
Obviously, Kanter and Ballard did not want Prudential and others
(particularly the IRS) to know about the payments and their
failure to report their income.
F. Phony Loans
Kanter transferred substantial amounts of money from IRA and
related entities to himself and Ballard (as well as other
entities such as KWJ Partnership) labeled as loans and recorded
as receivables in an effort to conceal distributions of the
income in question. Many of these purported loans were not
properly documented, and there was little evidence of any
meaningful payments of principal or interest. Kanter later
arranged sham sales of some of these receivables for $1, and in
other instances the loans were discounted and then written off as
bad debts. Still other IRA holdings were treated as worthless
securities. Similarly, Ballard transferred substantial amounts
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