-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.Page: Previous 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 Next
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