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The FPC Subventure Associates partnership (FPC Subventure)
was formed as of January 1, 1981. The partners of FPC Subventure
and their respective interests were: Lisle, 90 percent; the
Everglades Trust (Roger Baskes, trustee), 9 percent; and Burton
W. Kanter Revocable Trust (Kanter trustee), 1 percent. On
January 1, 1981, Kanter transferred his 8-percent interest in
Four Ponds to FPC Subventure, effectively transferring 90 percent
of his interest in Four Ponds to Lisle in exchange for a
receivable of $2,880 from Lisle.
A joint venture called One River Associates (One River) was
formed as of November 16, 1981. Schaffel and Torcivia were the
general partners. Kanter held an 8-percent interest in One
River. On January 1, 1982, Kanter transferred his interest in
One River to FPC Subventure in exchange for a $2,000 receivable
from FPC Subventure. Beginning in 1982, the 8-percent interest
in One River held by Kanter was treated as held by FPC
Subventure, and 90 percent of the income, loss, and distributions
were allocated to Lisle.
On April 5, 1982, Four Ponds distributed $400,000 to Kanter.
Kanter treated the distribution as a distribution to FPC
Subventure. FPC Subventure retained $5,000 and distributed
$395,000 to the partners, 90 percent to Lisle and 10 percent to
the Kanter trusts. An additional $33,600 was distributed by Four
Ponds to FPC Subventure through Kanter during 1982. During 1982
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