14.

       On September 1, 1973 (the same day OBA was formed), an

Illinois general partnership, Long Island Cable Communications

Development Co. (Long Island Cable), was formed.      Statland Exh.

2B.    Long Island Cable’s partners included class A partners and

one class B partner, OBA.    Id.     The Long Island Cable partnership

agreement stated the partnership was formed to negotiate for the

purchase of certain existing franchise rights and equipment

collectively constituting a cable television system in Nassau

County, New York, and thereafter to operate those franchise

rights by the construction of additional cable communication

facilities and marketing those facilities in New York and/or

Illinois.    Id.
               Kanter

employed the same tactics in attempting to improperly assign to

THC substantial fees he earned serving as trustee/investment

manager for Hi-Chicago Trust.   Thus, during the period 1977 to

1989, the record reflects Kanter engaged in an active and

sustained campaign to transfer his income to IRA, THC, and other

Kanter-related entities for the ultimate benefit of the Bea Ritch

Trusts.   We conclude Kanter is the grantor of the Bea Ritch

Trusts.

     In connection with the foregoing, Kanter failed to offer any

rational explanation for the addition of 60 trusts as

beneficiaries of the Bea Ritch Trusts after Kanter purportedly

renounced his interests in those trusts.   Kanter was the only

person vested with the power under the instrument creating the

Bea Ritch Trusts to appoint new trust beneficiaries.