Investment Research Associates - Page 281




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          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.                                  





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