- 346 - Issue 4. Whether Kanter is Taxable on the Income of the Bea Ritch Trusts for 1986 and 1987 FINDINGS OF FACT In the notice of deficiency for 1987, respondent determined that Kanter failed to report certain income, deductions, and losses of the Bea Ritch Trusts (sometimes BRT) which were reportable by him as the owner of BRT. Included in the income of BRT was 1986 net long-term capital gain from the partnerships Hempstead-Babylon (HB), Bergen-Westchester (BW), and Yorkshire Partners (YP) in the amounts of $1,143,248, $274,660 and $615,460, respectively, that had been reported on BRT returns for the fiscal year ended September 30, 1987. The capital gains of HB, BW, and YP were attributable to the sale by those partnerships of their interests in Long Island Cable Communications Development Co. (LICCDC), subsequently known as Cablevision Systems Development Co. (Cablevision). BRT originally became a partner of HB, BW, and YP through Oyster Bay Associates (OBA). OBA eventually distributed its interest in HB, BW, and YP to its partners, including BRT. The trust agreement dated January 1, 1969, established the Bea Ritch Trusts, Beatrice K. Ritch, Grantor, as a group of 25 trusts for the benefit of members of Kanter's family. Beatrice K. Ritch is Kanter's mother. Joel Kanter, Janis Kanter, and Joshua Kanter are the Kanters' children. Solomon Weisgal (Weisgal), was named trustee of each trust.Page: Previous 336 337 338 339 340 341 342 343 344 345 346 347 348 349 350 351 352 353 354 355 Next
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