- 243 - Kanter. It is clear that payments Schaffel made to IRA were in part for Kanter's service of introducing Schaffel to Ballard and Lisle, and that Kanter agreed to share the payments with Ballard and Lisle in a 45-45-10 split. Although it is also clear that the payments Schaffel made to Holding Co. were for Kanter's prior service in introducing Schaffel to Lisle, the record does not show that the funds flowed through from Holding Co. to Lisle. The payments at issue do not include the payments Schaffel made through FPC Subventure. Lisle included 90 percent of the FPC Subventure payments in the income reported on his returns. There is no evidence in the record that Kanter otherwise agreed to share or did share the fees from the Travelers transactions at issue here with Lisle. Thus, we find that none of the payments were paid to Lisle for his services. 4. The Schnitzer Arrangement In 1974, Schnitzer's holding company, Century, purchased Schnitzer-PMS (Fletcher Emerson at the time) for $1.3 million. The purchase price was based roughly on five times Fletcher Emerson's pretax earnings of approximately $250,000.44 At the time of the purchase, Schnitzer-PMS had been managing a relatively small number of Prudential's commercial properties. 44 Walter Ross was senior vice president of finance of Century Development Corp. at the time of Schnitzer's purchase of Fletcher Emerson. Ross testified that it was customary in the industry to base the purchase price of a service corporation such as Fletcher Emerson on the pretax income of the company.Page: Previous 233 234 235 236 237 238 239 240 241 242 243 244 245 246 247 248 249 250 251 252 Next
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