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FINDINGS OF FACT
SMP is a Delaware limited liability company with its
principal place of business in New York, New York. Corona is a
Delaware limited liability company with its principal place of
business in New York, New York.
The parties have stipulated many facts, which are
incorporated herein by this reference.
I. The Ackerman Group
A. Perry Lerner
During the taxable years at issue, Perry Lerner was the
managing member and the tax matters partner of SMP and Corona.
Mr. Lerner is a successful tax lawyer. He graduated from
Clairmont McKenna College in Clairmont, California, in 1965 and
from Harvard Law School in 1968. From 1968 to 1970, Mr. Lerner
worked as a clerk/attorney advisor to Judge Arnold Raum of the
U.S. Tax Court. From 1970 to 1976 and again from 1979 to 1980,
Mr. Lerner worked for the law firm of Kindall & Anderson in Los
Angeles. From 1976 to 1979, Mr. Lerner worked as an attorney
advisor for the U.S. Treasury Department, Office of International
Tax Counsel, in Washington, D.C.
9(...continued)
$211,407 adjustment for certain long-term capital gain that SMP
did not pass through on its 1998 partnership tax return.
Respondent does not seek to impose accuracy-related penalties
pursuant to sec. 6662 with respect to this adjustment.
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