- 330 - and Weisgal were required to account for their time and the $6,000 fee was based on that time. Although some of the commitment fees were paid by entities related to Kanter or Weisgal, the Kanters have provided no documents to show that the commitment fees paid by those entities were for Century Industries' consideration whether to purchase investments offered by those entities. Century Industries was not a partnership formed by a group of professionals, such as doctors, lawyers, or accountants, through which the professionals practice together. Kanter (an attorney) and Weisgal (an accountant) were the only partners in Century Industries who were professionals. Each individually owned only 1 percent of the partnership interests. Their family trusts owned the remaining 98 percent. Kanter and Weisgal used Century Industries to assign to the family trusts the fees they received for professional and promotional services. We find that the commitment fees were for professional and promotional services provided by Kanter and Weisgal and that they are the true earners of the income. Therefore, the income is not the income of Century Industries, and this Court has jurisdiction over the adjustments made in the notices of deficiencies. Respondent concedes that only half of the fees are Kanter's income. Kanter has not provided time records or any other evidence to establish that he may have provided less than half ofPage: Previous 320 321 322 323 324 325 326 327 328 329 330 331 332 333 334 335 336 337 338 339 Next
Last modified: May 25, 2011