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light of the entire record, the credibility determinations and
recommended holding in the STJ report were manifestly
unreasonable.
D. Analysis
In determining whether Kanter was the true settlor of the
Bea Ritch Trusts, we begin with the manner in which the trusts
were funded. The record indicates that if Bea Ritch transferred
any of her own assets to the 25 Bea Ritch Trusts, she transferred
no more than $100 to each trust or a total of $2,500.
Notwithstanding the lack of any evidence that Bea Ritch
transferred additional amounts to the Bea Ritch Trusts, Kanter
invites us to conclude the Bea Ritch Trusts were so deftly
managed that they were able to grow $2,500 in 1969 into many
millions during the years at issue without the benefit of
assignments of his earnings. Kanter did not introduce any
evidence indicating the trusts’ early investments were so
extraordinarily successful. We decline to accept such a
proposition where the record so clearly demonstrates (1) moneys
Kanter earned and assigned to or for the benefit of the Bea Ritch
Trusts represented the primary source of the trusts’ increasing
asset base, and (2) Kanter liberally used the Bea Ritch Trusts as
a source of loans.
We have already determined Kanter employed IRA and THC as
shams to receive, and shelter from taxation, income which Kanter
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