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distributions greater than their 1973 capital contributions to
OBA. Statland Exh. 14.
Kanter chose to participate in OBA. Statland Exh. 2; Baskes
Transcr. at 7-13. Kanter could have participated personally in
OBA but designated the Bea Ritch Trusts to participate in OBA up
to his 18-percent interest in Levenfeld/Kanter. Id. The Bea
Ritch Trusts acquired an 18-percent partnership interest in OBA
and contributed $18,000 to OBA. Statland Exhs. 2, 14. During
1974, the Bea Ritch Trusts received distributions from OBA
greater than the capital contributions of $18,000 they made to
the partnership in 1973. Statland Exh. 14.
On September 1, 1973 (the same day OBA was formed), an
Illinois general partnership, Long Island Cable Communications
Development Co. (Long Island Cable), was formed. Statland Exh.
2B. Long Island Cable’s partners included class A partners and
one class B partner, OBA. Id. The Long Island Cable partnership
agreement stated the partnership was formed to negotiate for the
purchase of certain existing franchise rights and equipment
collectively constituting a cable television system in Nassau
County, New York, and thereafter to operate those franchise
rights by the construction of additional cable communication
facilities and marketing those facilities in New York and/or
Illinois. Id.
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