Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 340

                                                 -40-                                                   
            personally represented.  Kanter also served as a director on                                
            several corporate and charitable organization boards.                                       
                  Kanter has made many investments through numerous entities,                           
            including corporations, partnerships, and family trusts.  Some of                           
            these family trusts are trusts the income of which is taxable to                            
            Kanter pursuant to the grantor trust provisions of sections 671                             
            through 678.  A number of Kanter’s family trusts own substantial                            
            stock interests in The Holding Co., Inc., a corporation that made                           
            extensive investments during the years at issue.                                            
                  Additionally, on occasion, Kanter and/or entities associated                          
            with him have entered into certain arrangements with various                                
            individuals, pursuant to which Kanter would use his business and                            
            professional contacts to assist such individuals either in                                  
            obtaining potential business opportunities or in raising capital                            
            for business ventures.  In exchange for such assistance from                                
            Kanter, these individuals agreed to share their profits or fees                             
            payable to an entity or entities associated with Kanter.23                                  


                  23  The STJ report incorrectly stated that entities Kanter                            
            represented provided assistance to various individuals in                                   
            obtaining business opportunities or in raising capital.  As                                 
            discussed in detail in the Court’s additional findings of fact,                             
            infra pp. 51, n. 27 (Weisgal testimony), 91-107 (Frey), 107-124                             
            (Schaffel), 124-131 (Schnitzer), and 131-152 (Eulich), there is                             
            no evidence (1) anyone at any Kanter-related entity provided the                            
            businessmen involved in the transactions in dispute (sometimes                              
            referred to as The Five) with assistance in obtaining business                              
            opportunities or in raising capital, or (2) any of these                                    
            businessmen were relying on anyone other than Kanter, in his                                
                                                                          (continued...)                




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