Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 203

                                                -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