Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 286

                                                -350-                                                   
            permitted THC to invest in his share of the CMS Investors                                   
            offering.  Kanter, Transcr. at 4198-4199.                                                   
                  Delta Partnership (Delta) was formed on the same date that                            
            CMS Investors was formed and CMS Investors acquired a 95.5-                                 
            percent partnership interest in Delta.  Exh. 9135.  Alpha                                   
            Partnership (Alpha) was formed in May 1979, and CMS Investors                               
            acquired an 85.5-percent partnership interest in Alpha.  Exh.                               
            9136.                                                                                       
                  In 1978, Delta made a substantial loan to another                                     
            partnership, Shelburne Associates (Shelburne), which the latter                             
            used to purchase several feature-length motion pictures.  Exh.                              
            9137.  In 1979, Alpha made a substantial loan to another                                    
            partnership, Century Associates (Century), which the latter used                            
            to purchase several feature-length motion pictures.  Exh. 9138.                             
            Respondent concedes Shelburne and Century both paid                                         
            substantial legal fees to the Levenfeld/Kanter law firm.                                    
            Respondent’s Opening Brief at 920, par. 1382.                                               
                  Shelburne and Century subsequently transferred to Delta and                           
            Alpha substantial amounts, characterized as bonus payments, and                             
            CMS Investors received distributable shares of these bonus                                  
            payments as a partner in Delta and Alpha.  THC, a CMS Investors                             
            partner, in turn received its distributable share of the bonus                              
            payments.  THC reported these payments as income on its income                              





Page:  Previous  340  341  342  343  344  345  346  347  348  349  350  351  352  353  354  355  356  357  358  359  Next

Last modified: May 25, 2011