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football coach. Four years later he joined the investment firm
of Smith, Barney, Harris & Upham (Smith, Barney). Farrell became
a successful retail salesman for Smith, Barney and eventually
influenced the investment of approximately $50 million. In 1982
Farrell became a partner at the investment management firm of
Spears, Benzak in midtown Manhattan. Over the next 12 years
Spears, Benzak increased the amounts it had under management from
approximately $150 million to nearly $3 billion.
On their joint 1982 Federal Income tax return, William and
Joan Spears reported gross income from wages, interest,
dividends, State and local tax refunds, and capital gains in
excess of $700,000. On their 1982 return, Vincent and Clotilde
Farrell reported gross income from wages, interest, dividends,
and State and local tax refunds in excess of $250,000.
Consequently, in the absence of significant deductions or
credits, petitioners in these consolidated cases were subject to
payment of Federal income taxes in substantial amounts.
Spears and Farrell are both partners in SAB Associates, a
limited partnership initially involved in tax straddle
investments. During 1981, the tax laws changed and as a
consequence SAB Associates was likely to realize substantial
gains. SAB Associates ceased engaging in tax straddle
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