Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 33

                                                -120-                                                   
            hotel on the property.  Exh. 986; Schaffel, Transcr. at 404-405.                            
            Torcivia and Schaffel each acquired a 36-percent general                                    
            partnership interest in One River Partnership, and Kanter held an                           
            8-percent limited partnership interest.  Exh. 986, sch. A.  Lisle                           
            was not a direct partner in One River Partnership.  Id.  Kanter                             
            made a $2,000 capital contribution to One River Partnership.  Id.                           
                  (iv).  Meyers’s Memorandum Regarding Four Ponds Partnership                           
                  A “memorandum to file” (apparently prepared by Meyers),                               
            dated April 14, 1982, stated that (1) although Kanter purportedly                           
            acquired a limited partnership interest in Four Ponds Partnership                           
            as a nominee, Kanter reported partnership items for Four Ponds                              
            Partnership for the taxable year 1980 on his personal tax return,                           
            (2) on January 1, 1981, Kanter (as nominee) transferred his 8-                              
            percent limited partnership interest in Four Ponds Partnership to                           
            Lisle (90 percent) and the Everglades Trusts (10 percent);57 (3)                            
            Lisle issued a promissory note to Kanter for $2,880; (4) Lisle                              
            and the Everglades Trusts formed the FPC Subventure Partnership;                            
            (5) the 8-percent Four Ponds limited partnership interest                                   


                  57  Contrary to this statement in the memorandum, FPC                                 
            Subventure’s tax return for 1981 indicated the five Everglades                              
            Trusts initially each acquired 1.8-percent limited partnership                              
            interests (for a total of 9 percent) and Kanter acquired a 1-                               
            percent limited partnership interest.  Exh. 9091.  By 1982, FPC                             
            Subventure’s tax returns indicated the five Everglades Trusts                               
            each held 2-percent limited partnership interests.  Id.                                     





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