-374- Issue XII. Whether Kanter Realized and Must Recognize Capital Gains as a Result of Transactions Involving Cashmere Investments Associates, Inc., During 1983 and Whether the Kanters May Use the Installment Method To Report Gains (STJ report at 145)149 FINDINGS OF FACT During the 1970s, Kanter was involved in a series of real estate development projects with developers Sam Zell (Zell) and Robert Lurie (Lurie). Kanter, Transcr. at 4241-4243, 4261. The development properties were owned by partnerships (real estate partnerships) and Kanter held interests in the real estate partnerships through the BWK Revocable Trust, the Everglades Trusts (Nos. 1-5), the BWK Family Trusts, and THC. Exh. 9156, items 3, 6. The BWK Revocable Trust and the Everglades Trusts were grantor trusts whose income was attributable to Kanter personally. Exhs. 130 and 130A; Kanter, Transcr. at 4235, 4261- 4262. The designated beneficiaries of the BWK Revocable Trust, the BWK Family Trusts, and the Everglades Trusts were members of Kanter’s family. Exhs. 453, 583, 9213, 130, 130A; Kanter, Transcr. at 4235, 4261-4262. During 1983, THC’s shareholders 149 The STJ report recommended holding that respondent is barred from making any determination concerning the taxable year 1983 on account of the expiration of the period of limitations governing assessment and collection for that year. As previously discussed, we determined that Kanter’s income tax returns for the years at issue were fraudulent, and, therefore, the period of limitations remains open pursuant to sec. 6501(c)(1).Page: Previous 364 365 366 367 368 369 370 371 372 373 374 375 376 377 378 379 380 381 382 383 Next
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