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Date of Amount of
Payment Payment
12/16/80 $80,000
1980 total 80,000
08/11/81 33,925
10/23/81 8,795
1981 total 42,720
10/13/82 19,247
1982 total 19,247
02/18/83 50,000
03/15/83 22,224
05/11/83 6,199
09/14/83 1,227
09/14/83 29,749
1983 total 109,399
HCT, Kanter as Trustee, filed Forms 1041, U.S. Fiduciary
Income Tax Returns, for its taxable years ended February 28,
1981, 1982, 1983, and 1984. Each of these returns was signed by
Kanter. On its returns for the taxable years ended February 28,
1981 through 1984, HCT claimed the following deductions for its
payments to Holding Co. pursuant to the carried interest:
Description Taxable Amount of
of Deduction Year Ended Deduction
Fiduciary fees 2/28/81 $80,000
Participation fees 2/28/82 42,720
Commissions 2/28/83 88,203
Commission expense 2/28/84 56,921
On its return for the taxable years ended February 28, 1982,
1983, and 1984, HCT did not claim any deduction for fiduciary
fees. Each of the returns of HCT for the taxable years ended
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