-41-
Petitioner Naomi R. Kanter, Kanter’s wife, was not involved
in any of the activities giving rise to this litigation. She is
a petitioner in these proceedings solely because she filed joint
Federal income tax returns with Kanter for the years at issue.
After paying a small amount of tax in 1978, Kanter paid no
Federal income taxes during 1979 through 1989.24 Kanter filed
Federal income tax returns that reported adjusted gross income
and income tax as follows:
Adjusted Gross Income
Year Income (Loss) Tax Paid Exhibit
1978 ($44,386) $1,671 120
1979 (105,084) -0- 121
1980 (155,026) -0- 123
1981 (53,614) -0- 125
1982 (287,536) -0- 127
1983 (819,449) -0- 128
1984 (804,482) -0- 130
1985 (954,695) -0- 130A
1986 (1,529,213) -0- 131
1987 (2,004,257) -0- 132
1988 (1,340,459) -0- 133
1989 (1,331,576) -0- 134
B. Claude M. Ballard (STJ report at 20-22)
Ballard was an employee of Prudential. He began his
employment with Prudential in 1948 in its real estate department.
23(...continued)
individual capacity, to assist them in obtaining business
opportunities and/or in raising capital.
24 Kanter paid small amounts of self-employment tax. Exh.
120.
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