-65-                                                   
            performed services for clients similar to those which TACI had                              
            provided to TACI’s clients.  For a short period in 1989, PSAC                               
            also established two accounts similar to the TACI Special E                                 
            Account and the TACI Special Account.                                                       
                  The fees PSAC received from its clients were not sufficient                           
            to fund PSAC’s operations.  From the time PSAC came into                                    
            existence in 1989 until the time Gallenberger purchased the stock                           
            of PSAC from the ARO Trust in 1990, PSAC borrowed over $100,000                             
            from BWK and THC to pay its employees’ salaries.  Gallenberger,                             
            Transcr. at 1980-1982, 1987, 2041.  BWK lent the money to PSAC                              
            either directly or through the TACI Special E Account.                                      
            Gallenberger, Transcr. at 1983-1984.                                                        
                  Beyond 1990, PSAC did not generate enough fees to cover its                           
            operational costs, continued to operate at a loss, and borrowed                             
            money from BWK.  Gallenberger, Transcr. at 1985-1986.  At the                               
            time the record in these cases was closed, PSAC had not repaid                              
            the loans from BWK.  Id.  When borrowing money, Gallenberger                                
            either contacted Kanter about the loan or went ahead and borrowed                           
            the money herself.  Gallenberger, Transcr. at 1986-1987.                                    
                  PSAC’s bookkeeping procedures and return preparation                                  
            procedures were essentially the same as TACI’s.  Gallenberger,                              
            Transcr. at 1988-1989, 2078.  Any questions that Gallenberger had                           
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