Gary Friedmann - Page 4




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             Number 1, and Friedmann Investors Number 2.  It appears                  
             that the business of these partnerships involved                         
             investments in real estate.  A number of clients of                      
             petitioner's Schedule C business, including some clients on              
             behalf of whom the expenditures at issue in this case were               
             allegedly made, were investors in one or more of these                   
             partnerships.  Petitioner was also the sole owner and                    
             employee of Friedmann Management Corp., which allegedly                  
             provided management services to the partnerships.                        
                  In addition to the instant case, petitioner prosecuted              
             a suit in District Court for refund of taxes paid with                   
             respect to his joint return for 1987.  Friedmann v. United               
             States, 107 F. Supp. 2d 502 (D.N.J. 2000).  In that case,                
             the court granted the Government's motion to dismiss one                 
             count of the complaint on the ground that it raised issues               
             that had not been set forth in the claim for refund, and                 
             the court granted summary judgment as to the other count                 
             of the complaint, involving certain consulting fees that                 
             petitioner claimed as an expense deduction on his Schedule               
             C, Profit or Loss From Business.  According to the court,                
             the consulting fees were not deductible because petitioner               
             had admitted in his complaint that the consulting fees were              
             not income to, nor a business expense incurred by,                       








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