Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 36

                                                -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.                                           




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