-304-
from TMT to himself, his wife, Mary Ballard, and his daughter,
Melinda Ballard, labeled as loans and stock investments. Most of
these purported loans were not properly documented, and there was
little evidence of any meaningful payments of principal or
interest. We also infer from notations in TMT’s books and
records that a so-called investment in Melinda Ballard’s company
was prearranged to be written off as a worthless security the
following year. Finally, Kanter received substantial transfers
from TACI, labeled as loans, that appear to amount to nothing
more than transfers of funds from THC to himself.
G. False and Misleading Documents
Kanter used false and misleading agreements with Schaffel
and Frey to create the appearance that Frey’s agreements were
with Zeus and THC as opposed to Kanter himself. Similarly, in
the Eulich/Essex Partnership transaction Kanter used false and
misleading representation and marketing agreements to create the
appearance that the partnership would provide services for GHM
and MHM when in fact MHM simply provided services for GHM.
H. Failure To Cooperate During the Examination Process
Kanter made it clear to IRS examination personnel from the
beginning that he did not intend to cooperate and he would frame
the issues for examination, not the IRS. We are also convinced
Kanter directed Gallenberger (an officer of TACI and PSAC) and
Weisgal (the trustee of the Bea Ritch Trusts) to withhold
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