Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 256

                                                -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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