-381-
Bayers was secretary, and Meyers was treasurer. Exh. 9156, item
4, at 2; Kanter, Transcr. at 4265.
On or about May 15, 1983, Kanter directed the transfer of
the grantor trusts’ real estate partnership interests to Cashmere
in what was intended to be a nontaxable exchange under section
351 in return for Cashmere common and preferred stock. Exh.
9156; Kanter, Transcr. at 4234-4245. THC, the BWK Family Trusts,
and the grantor trusts received Cashmere stock in exchange for
the real estate partnership interests as follows:
Shares of Stock
Shareholder Common Class A Preferred
BWK Revocable Trust 50 241.274
Everglades Trusts 400 257.226
BWK Family Trusts 30 --
THC 520 --
Exh. 9156, items 3, 5, 6.
Concurrently with the transfers described above, Kanter’s
grantor trusts also transferred to Cashmere eight promissory
notes with an aggregate face value of $498,500. Exh. 9156, item
7; Kanter, Transcr. at 4235-4238, 4244, 4249, 4267-4268.
Kanter’s grantor trusts transferred the following notes
receivable to Cashmere:
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