-323- conference with lenders, review identification of potential equity sources, and various meetings and updates with Angelo and John Geocaris. In sum, the record shows that Kanter and Weisgal were billing C&S at some sort of hourly rate, the services provided to Satcorp and C&S related to an evaluation of various forms and sources of debt financing those companies might pursue, and there was no mention in these letters that Century Industries was considering investing its own funds in any of the enterprises. Weighing the overwhelming objective evidence summarized above against Kanter’s and Weisgal’s testimony, we conclude the testimony was inherently implausible and not credible, and the STJ report was manifestly unreasonable in accepting that testimony in the light of the documentary record in these cases. We hold that one-half of Century Industries income during 1981 to 1984 and 1986 is income taxable to Kanter for those years.Page: Previous 313 314 315 316 317 318 319 320 321 322 323 324 325 326 327 328 329 330 331 332 Next
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