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personally earned from a variety of transactions. Kanter
attempted to assign to IRA and THC substantial amounts of income
which he earned in the form of payments from The Five. The Bea
Ritch Trusts owned all of IRA’s common stock, and they held a
substantial interest in THC.
Similarly, we conclude Kanter attempted to assign to Century
Industries (in which the Bea Ritch Trusts purportedly held a 49-
percent partnership interest) fees he earned evaluating
investment opportunities for various third parties. Kanter
employed the same tactics in attempting to improperly assign to
THC substantial fees he earned serving as trustee/investment
manager for Hi-Chicago Trust. Thus, during the period 1977 to
1989, the record reflects Kanter engaged in an active and
sustained campaign to transfer his income to IRA, THC, and other
Kanter-related entities for the ultimate benefit of the Bea Ritch
Trusts. We conclude Kanter is the grantor of the Bea Ritch
Trusts.
In connection with the foregoing, Kanter failed to offer any
rational explanation for the addition of 60 trusts as
beneficiaries of the Bea Ritch Trusts after Kanter purportedly
renounced his interests in those trusts. Kanter was the only
person vested with the power under the instrument creating the
Bea Ritch Trusts to appoint new trust beneficiaries. Under the
circumstances, we infer Kanter appointed the new beneficiaries
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