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evidence that Kanter repaid the approximately $1.3 million that
he owed TACI at the time of its bankruptcy. Considering all of
the circumstances, we infer that Kanter directed the transfer of
THC’S funds into TACI’s accounts as well as the subsequent
transfers from TACI’s accounts into his personal bank account.
Kanter did not intend to return these funds to either TACI or THC
because these funds belonged to Kanter.
G. The Flow of Funds From Four Ponds and One River Through
FPC Subventure to Kanter and Lisle
As previously discussed, Kanter acquired an 8-percent
limited partnership interest in Four Ponds Partnership and
transferred that partnership interest to FPC Subventure
Partnership. Lisle acquired a 90-percent interest in FPC
Subventure Partnership in exchange for a $2,880 promissory note.
Kanter then acquired an 8-percent limited partnership interest in
One River Partnership and transferred that interest to FPC
Subventure Partnership in exchange for a $2,000 promissory note.
As a result of his interest in FPC Subventure Partnership, Lisle
indirectly held partnership interests in Four Ponds Partnership
and One River Partnership. FPC Subventure Partnership’s primary
sources of income were Four Ponds Partnership and One River
Partnership. Exhs. 914-917.
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