-349-
Issue VI. Whether Kanter Received Unreported Income From CMS
Investors Partnership for 1982 to 1984 and 1987 to
1989 (STJ report at 121-129)139
FINDINGS OF FACT
Respondent determined in notices of deficiency issued to the
Kanters for 1982 to 1984 and 1987 to 1989 that Kanter failed to
report income of $191,461, $232,900, $290,785, $29,998, $127,249,
and $279,596, respectively.140 As discussed in detail below,
these adjustments are attributable to respondent’s determination
that Kanter attempted to assign to THC income that he earned in
respect of transactions involving CMS Investors Partnership (CMS
Investors).
Much as in the Cablevision transaction (discussed supra
Issue V), members of the Levenfeld/Kanter law partnership and/or
entities established for the benefit of their families were
offered and acquired partnership interests in CMS Investors
during 1978. Kanter, Transcr. at 4105-4107; Exh. 9134. Kanter
139 The Court’s disposition of this issue represents in
large measure a wholesale adoption of the recommended findings of
fact and conclusions of law set forth in the STJ report.
140 These adjustments were resolved in petitioners’ favor
and the decisions entered by the Court at docket Nos. 24002-91
(taxable year 1987), 26918-92 (taxable year 1988), and 25981-93
(taxable year 1989), on Sept. 24, 2001, were not appealed, and
are otherwise final. See secs. 7481(a)(1), 7483. Respondent,
however, challenges the recommended findings of fact and
conclusions of law in the STJ report, and, therefore, we are
obliged to address the CMS Investors Partnership issue for 1982
to 1984.
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