-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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