-52-
9071, 9085. Kanter and his law firm provided legal services to
IRA. Gallenberger, Transcr. at 1990.
From 1976 through 1980, Schott, Weisgal, and Patricia Grogan
(Grogan) served as IRA’s directors. Exh. 4. Grogan was an
accountant who began working at Kanter’s law firm in the mid-
1970s. Grogan, Transcr. at 1395-1396. From 1981 through 1989,
Freeman served as IRA’s director. Exhs. 4, 9071.
Ballard and Lisle were never shareholders, officers,
directors, or employees of IRA. Exh. 4. However, in December
1981, IRA issued a check to Ballard in the amount of $12,500–-an
amount identified in the memo section of the check as a
director’s fee. Exh. 3007. Ballard cashed the check, and IRA
deducted the payment as a director’s fee on its 1981 tax return.
Id.; Ballard, Transcr. at 218; Exhs. 14, 9071.
d. IRA’s Subsidiaries
IRA owned, from time to time, controlling interests in
several subsidiary corporations. These subsidiary corporations
included Brickell Enterprises, Inc., Cedilla Co., Cedilla
Investment Co., IRA Florida Apartments, Inc., KWJ Corp., Zeus
Ventures (Zeus),28 Carlco, Inc. (Carlco), TMT, Inc. (TMT), and
BWK, Inc. (BWK). Carlco, TMT, and BWK are discussed in
28 Zeus Ventures (Zeus), is discussed with regard to the
Frey transactions described infra pp. 91-107.
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