-123- 417-421 (Lisle). The record shows that Four Ponds Partnership and One River Partnership (1) reported net losses in 1981 to 1984 and 1987 to 1989 totaling $1,067,131, and (2) made cash distributions to its partners in 1981 to 1984 and 1987 to 1989 totaling $731,080. Respondent’s Opening Brief at 349-350, par. 1016, and Petitioners’ Reply Brief at 663-664; Exhs. 125-134 (Kanter); Exhs. 417-421 (Lisle); Exhs. 9090-9094 (FPC Subventure Partnership tax returns and Schedules K-1 for Four Ponds Partnership and One River Partnership). Approximately 7 percent of Four Ponds’ and One Rivers’ partnership losses, described above, flowed through to Lisle through FPC Subventure Partnership. Exhs. 417-421. Tax effects aside, during the period 1981 to 1989 Lisle received at least $682,520 in cash distributions from FPC Subventure Partnership.60 Exhs. 9090-9094, 417-421. Consequently, FPC Subventure Partnership served for Lisle the dual purposes of (1) a tax shelter, and (2) a source of substantial cashflows. 59(...continued) The Five to IRA and THC. As discussed in additional findings of fact in the text that follows, we are convinced Kanter used FPC Subventure Partnership as a conduit to facilitate the transfer to Lisle of his share of fees that Schaffel paid to THC on Travelers transactions. 60 FPC Subventure Partnership’s tax returns for 1985 and 1986 apparently were not made part of the record.Page: Previous 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 Next
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