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