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who passed away in July 1987. Pursuant to Rule 63(a), this Court
ordered that "Estate of Roger W. Dornbrock, Deceased, Maryn J.
Dornbrock, Personal Representative" be substituted for "Roger W.
Dornbrock" as a petitioner in this case.
Throughout the entire process just described, the attorney,
Mr. Young, represented the taxpayers in the lead cases that were
tried, and he continued as attorney for the taxpayers in this
case, which had been severed from the lead cases. Mr. Young was
in direct contact with only one of the program participants,
Frank C. Pasternak (Mr. Pasternak). Mr. Pasternak was a
certified public accountant whose clients included one of the
organizers of the Pop Phonomasters program. Mr. Pasternak had
accepted the responsibility of acting as "Co-tenancy Operator"
(CTO) for the Pop Phonomasters program. By signing the
aforementioned Offer, each Pop Phonomasters participant,
including Mr. Dornbrock, appointed Mr. Pasternak as his or her
attorney in fact and authorized him to execute, on behalf of each
participant, the Co-tenancy and Operating Agreement, the
Phonomasters Lease Agreement, and the Phonomasters Marketing
Agency Agreement. Each participant also authorized Mr. Pasternak
to execute any documents required under section 48(d) and section
1.48-4(g), Income Tax Regs., to pass through investment tax
credits from the lessor to the lessees. In his capacity as CTO,
Mr. Pasternak was given, subject to the other participants'
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