-275- In 1982, Kanter also transferred his 8-percent limited partnership interest in One River Partnership to FPC Subventure Partnership in exchange for a $2,000 promissory note. During the years at issue, Kanter (who held an interest in FPC Subventure through grantor trusts) and Lisle reported distributive shares of FPC Subventure’s partnership items of income, loss, deduction, and credit on their individual tax returns. However, 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. Approximately 7 percent of Four Ponds’ and One Rivers’ partnership losses, described above, flowed through to Lisle through FPC Subventure Partnership. In addition to these favorable tax effects, during the period 1981 to 1989 Lisle received at least $682,520 in cash distributions from FPC Subventure Partnership.116 Consequently, FPC Subventure Partnership served for Lisle the dual purposes of (1) a tax shelter, and (2) a source of substantial cash distributions. Kanter structured FPC Subventure Partnership as a 116 FPC Subventure Partnership’s tax returns for 1985 and 1986 apparently were not made part of the record.Page: Previous 265 266 267 268 269 270 271 272 273 274 275 276 277 278 279 280 281 282 283 284 Next
Last modified: May 25, 2011