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also read some periodicals discussing the perceived oil shortage.
Finally, petitioner discussed the profitability of the recycling
transactions with promoters such as Bambara, Taggert, and
Giovannone. These individuals assured petitioner that the
Sentinel recyclers were unique. Petitioner did not consult an
independent consultant or appraiser with respect to the value of
the Sentinel recyclers.
Petitioner never made any profit from his investments in the
Partnerships during any year. The projected tax benefits for the
initial year of investment described in the Partnerships'
offering memoranda greatly exceeded petitioner's investments in
the Partnerships. In fact, the tax benefits actually claimed by
petitioner on his tax returns for the initial year of investment
in the Partnerships greatly exceeded his investments in the
Partnerships.
Petitioner's Federal income tax returns for the years in
issue were prepared by accountant who had prepared petitioner's
returns for many years.
In November 1983, respondent mailed petitioner a so-called
"no-change letter" regarding the taxable year 1982. The letter
stated as follows:
We are pleased to tell you that our examination of
your tax returns for the above periods shows no change
is required in the tax reported. Your returns are
accepted as filed.
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