-382-
Maker Payee Amount
THC Everglades Trusts $90,000
Burton W. Kanter Everglades Trusts 34,230
Beach Trust Burton W. Kanter 128,725
HELO Everglades Trusts 94,800
GL’s Associates Everglades Trusts 38,000
ARO Trusts Burton W. Kanter 25,045
Baroque Trusts Burton W. Kanter 66,000
BWK Children’s Trust Burton W. Kanter 21,700
Total 498,500
Exh. 9156, index and item 7; Kanter, Transcr. at 4269-4270. Each
promissory note listed above was dated May 1, 1983, and was due
and payable on August 31, 1983. Respondent’s Opening Brief at
1024, par. 1538; Petitioners’ Reply Brief at 1348.
The trustee of Beach Trust was Albert Morrison, the grantor
was Kanter, and the beneficiaries were members of Kanter’s
family. Exh. 9216. The trustee of the Baroque Trusts was
Patricia Grogan, the grantor was Kanter, and the beneficiaries
were members of Kanter’s family. Exh. 9219. For Federal tax
purposes, Kanter was the “deemed owner” of the Baroque Trusts,
and income therefrom generally was reportable on Kanter’s
individual Federal income tax returns. Exh. 9111, Bates Nos.
000125-000127.
Kanter intended that, if the promissory notes were accorded
bases equal to face values, the promissory notes would increase
the aggregate basis of the property the grantor trusts
transferred to Cashmere; i.e, the promissory notes’ bases would
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