-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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