-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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