Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 449

                                                 -91-                                                   
                  2.  Bruce Frey’s Payments to IRA From 1980 Through 1985 and                           
            to THC in 1981, 1983, 1984, and 1987 (STJ report at 37-                                     
            42)                                                                                         
                  Bruce Frey was a certified property manager, real estate                              
            broker, and the principal in D.M. Interstate Management, Inc.                               
            (D.M. Interstate), a real estate property management company that                           
            was an S corporation.49  By January 1980, Frey organized a                                  
            corporation, BJF Development, Inc. (BJF, Inc.), to engage in the                            
            business of condominium conversions.  Exh. 5800; Frey, Transcr.                             
            at 653-654.  As discussed in detail below, Frey, his business                               
            associate, James Wold (Wold), and BJF, Inc. (as general                                     
            partners), organized a number of limited partnerships for the                               
            purpose of carrying out condominium conversion projects, selling                            
            the condominium units, and providing ongoing management services                            
            for the condominium association.  Exh. 5800; Frey, Transcr. at                              
            659-660, 663.                                                                               
                  On June 15, 1984, Frey, Wold, and BJF, Inc., as general                               
            partners, and TSG Holdings, Inc., FWID, Ltd., and THC formed a                              
            limited partnership known as BJF Development, Ltd. (BJF                                     
            Partnership), to engage in condominium conversion projects and                              

                  49  The second, third, and fourth sentences in the opening                            
            paragraph of the STJ report describing business entities operated                           
            by Bruce Frey (Frey) are incorrect.  A correct statement of those                           
            facts is set forth in additional findings of fact in the text                               
            that follows.                                                                               






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