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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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