-66-                                                   
            regarding accounting matters were answered by Kanter or Freeman.                            
            Id.                                                                                         
            PSAC was located at Kanter’s law firm, Neal, Gerber &                                       
            Eisenberg.  George, Transcr. at 1282-1283.  PSAC moved                                      
            simultaneously with Kanter’s law firm.  George, Transcr. at 1283-                           
            1284.                                                                                       
            II.  Introductory Statement and Brief Introduction of The Five                              
                  (STJ report at 24-28)                                                                 
                  A.  The STJ Report                                                                    
                  A certain group of persons and/or entities has been referred                          
            to by the parties collectively as “The Five”.  The Five, for the                            
            most part, play a prominent role in connection with the                                     
            additions to tax for fraud.  Respondent contends that The Five                              
            made payments over a number of years to Kanter, Ballard, and/or                             
            Lisle that were kickbacks or payoffs devised by Kanter, Ballard,                            
            and/or Lisle.  These various transactions or activities involving                           
            The Five and the payments by them have been identified and                                  
            referred to by respondent as the “Prudential scheme”, the                                   
            “Travelers transaction”, and the “Kanter transaction”.  For                                 
            instance, under the Prudential scheme, respondent contends that                             
            Ballard and Lisle used their positions at Prudential to influence                           
            and cause Prudential to award business to individual members of                             
            The Five.  In return for Ballard’s and Lisle’s services, each                               
            member of The Five made payments to an entity or entities owned                             
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