-384-
later changed its name to Windy City, Inc. Kanter, Transcr. at
4536.151
On July 12, 1983, the BWK Revocable Trust, the Everglades
Trusts, THC, and the BWK Family Trusts sold all of their Cashmere
stock (common and preferred shares) to Waco for promissory
installment notes totaling approximately $1.5 million. Exh.
9156, items 8, 9. The Waco promissory notes provided for
payments in 1983 and 1984 and balloon payments in 1993. Id. The
Waco promissory notes were secured by the Cashmere stock, subject
to Waco’s option to substitute as collateral the guaranties of
its shareholders, the Bea Ritch Trusts, which would pledge
various partnership interests (known in the aggregate as
“Cablevision”). Exh. 9156, item 7, at 3. Sharon Meyers, on
behalf of Waco and the Bea Ritch Trusts, subsequently exercised
this option to substitute collateral. Exh. 9156, item 46.
Kanter reported installment sale income on Forms 6252
attached to his Federal income tax returns for 1984 and 1985.
Exhs. 130, 130A. Kanter did not present any evidence to
151 As previously mentioned supra p. 176, Zeus purchased
Waco/Windy City, Inc. stock in 1986. In addition, Kanter sold to
Windy City certain promissory notes, bonds, and shares of stock
in a failed attempt to generate capital losses for 1987. See
Issue XXIII, infra.
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