-57-
discussed in the flow-of-funds analysis below, additional
findings of fact are warranted.33
THC was incorporated as a subchapter C corporation on
December 8, 1976. Exh. 153. THC owned several subsidiary
corporations including the Citra Co., Active Business Corp.,
Zion Ventures, Inc.,34 Harbor Exchange Lending Operation (HELO),35
LBG Properties, Inc., The Nominee Corp., Oil Investments, Ltd.,
and Tanglewood Properties, Inc. Exhs. 153, 154, 156-160.
THC held numerous partnership interests during the period in
question. Id.
a. THC’s Shareholders, Officers, and Directors
The shareholders statement on each of THC’s tax returns
shows that Kanter owned THC’s voting stock as follows: 1977--75
percent; 1978--76 percent; 1979--76 percent; 1980--76 percent;
1983 to 1986--not more than 50 percent.36 Exh. 153, at 25; Exh.
154, at 14, l. 10; Exh. 156, at 13, l. 10; Exhs. 157-160. THC’s
shareholders between 1981 and 1983 included Kanter, his immediate
33 Payments THC received from The Five (in this case
Schaffel, Frey, and Eulich) are summarized infra pp. 207-208.
34 Zion Ventures, Inc. (Zion), is discussed with regard to
the Frey transactions described infra pp. 91-107.
35 Harbor Exchange Lending Operation (HELO) is discussed
with regard to the flow-of-funds analysis infra pp. 196-205.
36 The record does not include a complete set of THC’s
corporate minutes books, stock ledgers, or stock registers.
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