-377-
interested in purchasing all of the real estate partnership
interests listed above. Kanter, Transcr. at 4242-4244, 4253-
4254, 4265, 4302-4303. Although Kanter was interested in selling
the partnership interests, he was concerned the transaction would
trigger significant capital gains because his grantor trusts had
negative capital accounts in the real estate partnership
interests; i.e., their liabilities exceeded their bases. Kanter,
Transcr. at 4244. Kanter’s grantor trusts’ negative capital
accounts for the partnership interests in question, as of May 15,
1983, totaled $476,888.60, as follows:
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