Albert R. and Phyllis F. Dworkin - Page 7

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            tax and business energy credits totaling $63,612.  Respondent                                  
            disallowed petitioners' claimed operating loss and credits                                     
            related to Northeast for taxable year 1981.                                                    
                  Petitioner Albert Dworkin is a well-educated and                                         
            sophisticated businessman, investor, and tax professional.                                     
            Petitioner received a B.S. degree from New York University and an                              
            LL.B. degree from Fordham Law School.  He is a certified public                                
            accountant (C.P.A.) and has been admitted to the New York bar.                                 
            Petitioner was employed as an internal revenue agent from 1941 to                              
            1945.  In 1945 he joined the accounting firm of David Berdon &                                 
            Co.; he became a partner in that firm in 1952.  While at David                                 
            Berdon & Co., petitioner represented clients by assisting Federal                              
            examiners in income and estate tax return examinations; resolved                               
            disputes at the District Conference and Appeals Office levels of                               
            the Internal Revenue Service (IRS); supervised and assisted in                                 
            the preparation of tax returns; and researched and drafted                                     
            memoranda addressing tax issues.  For a number of years,                                       
            petitioner was also a member of the Federal Taxation Committee of                              
            the American Institute of Certified Public Accountants.                                        
                  Petitioner left David Berdon & Co. in 1970.  He has since                                
            acted as a consultant, engaged in various business matters, and                                
            made numerous business investments.  Between 1952 and 1980                                     
            petitioner held minority interests in 16 different unincorporated                              
            entities.  Two of these were oil drilling operations and 14 were                               
            real estate interests.  From 1977 to 1988 petitioner held                                      

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