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Petitioner resided at the Federal Correctional Institute in
Danbury, Connecticut, at the time that his petition was filed.
Petitioner graduated from the Wharton Business School at the
University of Pennsylvania in 1957 and from Harvard Law School in
1960. Between 1960 and 1964, petitioner was employed by the
office of Tax Legislative Counsel, U.S. Department of the
Treasury; served with Army Intelligence; and was employed by the
accounting firm of Touche, Ross & Co. In 1964, petitioner
commenced the private practice of law in a partnership that later
became a professional corporation (Bergman & Barth). Bergman &
Barth specialized in tax matters, estate planning, pensions, and
corporate planning. Petitioner was the managing partner and
prepared the tax returns for Bergman & Barth. (He was admitted
to the U.S. Tax Court bar May 5, 1970.)
An agreement dated July 29, 1976, under which Bergman &
Barth bought petitioner's shares in that firm included the
following terms:
2. Buyer agrees to pay Barth [petitioner] for
said shares of capital stock the principal sum of One
Hundred Thousand ($100,000.00) Dollars in manner and
form as follows:
a. One Hundred Thousand ($100,000.00)
Dollars thereof at the Closing hereinafter described in
manner and form as set forth in Schedule A attached.
3. Buyer agrees to pay Barth deferred
compensation in the amount of Two Hundred Fifty-one
Thousand One Hundred Twenty Dollars and Forty-nine
Cents ($251,120.49) and Barth agrees that he will
report said sum as earned income when paid on his
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