Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 412

                                                 -54-                                                   
            Exhs. 56, 79.  Meyers was named trustee of the Christie and                                 
            Orient trusts.  Id.  Members of Lisle’s family were named as                                
            beneficiaries of the Christie Trust, and members of Ballard’s                               
            family were named as beneficiaries of the Orient Trust.  Id.                                
                  Carlco, TMT, and BWK were so-called shelf corporations that                           
            Kanter first incorporated in 1982 but remained dormant until late                           
            1983.  Kanter, Transcr. at 3604-3605.  In December 1983, IRA                                
            acquired 1,000 shares or 100 percent of the common stock of each                            
            of Carlco, TMT, and BWK.  Exh. 18, at 7.  IRA paid $6,000 to each                           
            of the corporations for the shares of stock.  Exhs. 68, 92, 113.                            
                  In December 1983 and January 1984, Carlco, TMT, and BWK each                          
            issued preferred shares of stock.  Carlco preferred shares were                             
            issued to the Christie Trust (Lisle’s family trust); TMT                                    
            preferred shares were issued to the Orient Trust (Ballard’s                                 
            family trust); and BWK preferred shares were issued to the BK                               
            Children’s Trust (one of the Bea Ritch Trusts).  As a result of                             
            those trusts’ ownership of these preferred shares, Carlco, TMT,                             
            and BWK no longer qualified to be members of IRA’s consolidated                             
            group of corporations for tax purposes and were not included in                             
            the consolidated returns IRA filed.  For 1984 and thereafter,                               
            Carlco, TMT, and BWK, each filed separate Federal corporate                                 
            income tax returns.  The record does not include a complete set                             







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