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by the trusts or recently transferred to them by or at the
direction of Kanter.
The specific notes receivable transferred to Cashmere along
with the partnership interests were as follows:
Maker Payee Amount
Holding Co. Everglades Trusts 1-5 $90,000
Burton W. Kanter Everglades Trusts 1-5 34,230
Beach Trust Burton W. Kanter 128,725
HELO Everglades Trusts 1-5 94,800
GO's Associates Everglades Trusts 1-5 38,000
ARO Trusts Burton W. Kanter 25,045
Baroque Trusts Burton W. Kanter 66,000
BWK Children's Trust Burton W. Kanter 21,700
Total 498,500
Each note was dated May 1, 1983, and was, by its terms, due
and payable on August 31, 1983. Each of the notes from the Beach
Trust ($128,725), Baroque Trusts ($66,000), BWK Children's Trusts
($21,700), and ARO Trusts ($25,045) stated that they were
transferred, sold, and assigned to the BWK Revocable Trust as of
May 1, 1983. However, the Beach Trust note was not actually
"transferred sold and assigned to the BWK Revocable Trust" prior
to August 31, 1983.
The trustee of the Beach Trust was Albert Morrison
(Morrison), the grantor was Kanter, and the beneficiaries were
members of Kanter's family. The trustee of the Baroque Trusts
was Grogan, the grantor was Kanter, and the beneficiaries were
members of Kanter's family. For Federal tax purposes, Kanter was
the "deemed owner" of the Baroque Trusts, and income of these
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