Alfred J. Martin - Page 5




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          for Zobrist.  Matthias and Berg left Zobrist in 1988 to form                
          their own law firm, Matthias & Berg.  Matthias became lead                  
          counsel in the test case for the Manhattan group around 1986.               
          Zobrist, and later Matthias & Berg, represented more than 4,000             
          limited partners.  Zobrist and Matthias & Berg filed several                
          petitions for most of the limited partners that they represented.           
          The two firms filed more than 14,000 petitions for limited                  
          partners.                                                                   
               The following typically occurred when Matthias & Berg                  
          prepared petitions for Manhattan limited partners:  (1) The firm            
          received a letter with a copy of a notice of deficiency from the            
          limited partner, or an accountant or other attorney; (2) the                
          paralegals prepared petitions on behalf of anyone named in the              
          notice of deficiency; (3) Matthias or Berg reviewed and signed              
          the petition; (4) the paralegals sent a transmittal letter to the           
          limited partner with a copy of the petition; (5) the paralegals             
          placed copies of any correspondence in the client’s case file;              
          and (6) the limited partner paid the firm a $120 fee for each               
          petition filed.                                                             
          C.   The Notices of Deficiency and Petitions in These Cases                 
               1.   Tax Years 1981 and 1982 (Docket No. 32146-86)                     
               Petitioner filed his income tax return for 1981 on December            
          31, 1982, and for 1982 on January 2, 1984.  Respondent mailed a             
          notice of deficiency for tax years 1981 and 1982 to petitioner on           
          May 15, 1986, at 1 Lily Pond Court, Rockville, Maryland, his last           




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