Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 246

                                                -314-                                                   
                  From 1983 through 1986, Kanter and Weisgal received the                               
            following guaranteed payments from Century Industries:                                      
                        Year         Kanter            Weisgal                                          
                        1983        $2,000             $2,000                                           
                        1984        12,000             --                                               
                        1985        7,500              --                                               
                        1986        6,000              6,000                                            
                  Beginning in about 1987, Century Industries made certain                              
            investments that required significant additional capital                                    
            contributions from its partners.  Some of these investments                                 
            proved to be unsuccessful.  Ultimately, in 1988 or 1989, the                                
            partnership was dissolved.  Its affairs were wound up and its                               
            remaining investments with any value were distributed to the                                
            partners.                                                                                   
                  Century Industries filed Forms 1065 (U.S. Partnership                                 
            Returns) for 1980 through 1986 which demonstrate that Century                               
            Industries made only a relatively small number of investments and                           
            incurred minimal expenses during that period.  On these returns,                            
            the partnership reported the following items of income and                                  
            expenses:                                                                                   













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