-68- personally earned that he directed be paid to IRA or other entities he controlled and, as to which, Kanter failed to report on his individual income tax returns. Respondent maintains that the failure of Kanter, Ballard, and Lisle to report the Prudential scheme, Travelers transaction, and Kanter transaction income constituted fraud under section 6653(b), for 1978 through 1989. The entities that make up The Five and a brief description of each follows: (1) Hyatt Hotels Corp., a subsidiary of Hyatt Corp. (Hyatt). Hyatt manages hotels in the United States, Canada, and the Caribbean. As indicated previously, members of the Pritzker family control the ownership of Hyatt. Kanter represented the Pritzkers for years as their attorney. In 1979, IRA acquired KWJ Corp., a corporation that had been receiving certain “commission” payments from Hyatt on the management fees Hyatt earned in operating the Hyatt Embarcadero Hotel at San Francisco, California. The Hyatt Embarcadero Hotel had been developed and was owned by a joint venture in which Prudential was a participant. The commission payments, respondent contends, constituted part of the kickback scheme. (2) Bruce J. Frey, D.M. Interstate, the B.J.F. Development Co. Partnership, and BJF, Inc. Bruce J. Frey was the principal in each of these latter entities. Mr. Frey, through these entities, managed apartments, office buildings, and commercialPage: Previous 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 Next
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