-121- constituted a capital contribution to FPC Subventure Partnership, and (6) Four Ponds Partnership made a $400,000 cash distribution to Kanter on April 5, 1982, and Kanter transferred the distribution to FPC Subventure Partnership, which distributed $355,500 to Lisle and $39,500 to the Everglades Trusts, leaving $5,000 in FPC Subventure Partnership’s account. Exh. 9093.58 On May 3, 1982, Kanter wrote a letter to Schaffel which stated in pertinent part: The purpose of this letter, as we discussed, is to reflect the fact that I have been holding a partnership interest in Four Ponds Center Associates in my name on behalf of another partnership, known as FPC Subventure Associates. There are two participants in that partnership, trusts for the benefit of members of my family and associates. [Exh. 194.] The letter also stated that the Four Ponds partnership agreement would not need to be modified so long as Kanter continued to hold the partnership interest in his name. Id. Schaffel and Torcivia were not aware Lisle was a partner in FPC Subventure Partnership. Schaffel, Transcr. at 407; Torcivia, Transcr. at 371. In 1982, Kanter transferred his 8-percent limited partnership interest in One River Partnership to FPC Subventure 58 Contrary to this statement in the memorandum, FPC Subventure’s tax return for 1982 indicated the partnership made a cash distribution of $427,600, and a Schedule K-1, Partner’s Share of Income, Deductions, and Credits, issued to Lisle indicated he received $384,840 (or 90 percent) of that amount. Exh. 9091.Page: Previous 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 Next
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