-380-
The Holding Co. C & W Investors
The Holding Co. First Commitment & Dev.
The Holding Co. 332 Equity Partnership
The Holding Co. Katy Land Company
Total FMV--The Holding Co. $520,000.00
Exh. 9166.
Because an unqualified transfer of the partnership interests
of the grantor trusts to Zell would involve the assumption of
liabilities in excess of the trusts’ bases in the partnership
interests, Kanter (the owner of those interests by virtue of the
grantor trust provisions (sections 671-677) would be required to
recognize capital gains on the sale to Zell. In an effort to
avoid this result, Kanter directed a series of transactions in
1983 which ultimately resulted in the transfer of both cash and
the real estate partnership interests from his grantor trusts to
Zell. The transfers took place in three stages described below.
A. Transfer of Real Estate Partnership Interests to Cashmere
Cashmere Investments Associates, Inc. (Cashmere), was an
inactive “shelf” corporation incorporated in Delaware in 1982 and
controlled by Kanter. Exh. 9156; Kanter, Transcr. at 4231-4246,
4249, 4260-4261, 4266. Cashmere’s board of directors consisted
of Sharon Meyers and Weisgal. Exh. 9156, items 4, 10(g); Kanter,
Transcr. at 4264-4265. Weisgal was Cashmere’s president, Sharon
Page: Previous 370 371 372 373 374 375 376 377 378 379 380 381 382 383 384 385 386 387 388 389 NextLast modified: May 25, 2011