-213-
that his capital account at the end of 1989 was negative
$2,745,636. Exh. 9092.
A Schedule K-1 that Four Ponds issued to Kanter for 1989
showed that Kanter/FPC Subventure Partnership’s capital account
at the end of 1989 was a negative $1,288,755. Exh. 215. A
Schedule K-1 that One River Partnership issued to Kanter for 1989
showed that Kanter/FPC Subventure Partnership’s capital account
at the end of 1989 was negative $1,767,981. Exh. 9094.
FPC Subventure Partnership was a conduit that Kanter used to
transfer to Lisle a share of the payments that Schaffel made to
THC on Travelers transactions from 1984 to 1986.
V. Additional Findings of Fact Regarding the Examination
Process and Summons Enforcement Proceedings
As previously discussed, the Kanters paid a small amount of
Federal income tax for 1978. The Kanters filed tax returns for
1979 to 1989 reporting no tax liability.
A. Failure To Cooperate During the Audit
During the late 1980s, the IRS began an examination of
Kanter’s and IRA’s tax returns. Lunk, Transcr. at 1040-1042.
When Kanter met with IRS examiners and they requested certain
documentation, Kanter informed the examiners that he would frame
the issues in the case, not the IRS. Dion, Transcr. at 831-834.
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