-212-
Four Ponds Partnership and One River Partnership (1)
reported net losses for 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; 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).104
Approximately 7 percent of Four Ponds Partnership’s and One River
Partnership’s losses, described above, flowed through to Lisle
from FPC Subventure Partnership. Exhs. 417-421.
The cash distributions made to FPC Subventure Partnership
from Four Ponds and One River were deposited into the TACI
Special E Account. Exh. 205; Exh. 176, at 10, 15; Exh. 174, at
126-127. Shortly after the money from Four Ponds and One River
was deposited into the TACI Special E Account, 90 percent of that
money was distributed directly to Lisle. Exh. 176, at 10, 15;
Exhs. 914-917; Exh. 5415. During the period 1981 to 1989, Lisle
received a total of $682,520 in cash distributions from FPC
Subventure Partnership. Exhs. 9090-9094, 417-421. A Schedule K-
1 that FPC Subventure Partnership issued to Lisle for 1989 showed
104 FPC Subventure Partnership’s tax returns for 1985 and
1986 apparently were not made part of the record.
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