-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.
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