-274-                                                   
            discussed below, Kanter passed at least a portion of Lisle’s                                
            share of this income to Lisle through FPC Subventure Partnership.                           
                  a.  FPC Subventure Partnership                                                        
                  Kanter, purportedly as a nominee, acquired 8-percent limited                          
            partnership interests in both Four Ponds Partnership and One                                
            River Partnership--two partnerships organized by Schaffel and                               
            Torcivia for real estate development projects.  A “memorandum to                            
            file”, dated April 14, 1982, stated (1) on January 1, 1981,                                 
            Kanter (as nominee) transferred his 8-percent limited partnership                           
            interest in Four Ponds Partnership to Lisle (90 percent) and the                            
            Everglades Trusts (10 percent); (2) Lisle issued a promissory                               
            note to Kanter for $2,880; (3) Lisle and the Everglades Trusts                              
            formed FPC Subventure Partnership; (4) on April 5, 1982, Four                               
            Ponds Partnership made a $400,000 cash distribution to Kanter;                              
            and (5) Kanter transferred the Four Ponds distribution to FPC                               
            Subventure Partnership, which distributed $355,500 to Lisle and                             
            $39,500 to the Everglades Trusts, leaving $5,000 in FPC                                     
            Subventure Partnership’s account.115                                                        
                  Contrary to Kanter’s testimony, Schaffel and Torcivia were                            
            not aware that Lisle was a partner in FPC Subventure Partnership.                           
                  115  Contrary to the “memorandum to file”, FPC Subventure’s                           
            tax return for 1982 and a Schedule K-1 issued to Lisle indicate                             
            the partnership made a cash distribution of $427,600 and Lisle                              
            received $384,840 (or 90 percent) of that amount.                                           
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