- 3 - remained at Bear, Stearns & Co. until the summer of 1980, the year he founded MBMC. James Russell, a lawyer with expertise in tax, estate, corporate, and investment matters, was a special limited partner in charge of investment banking at MBMC.2 Mr. Russell first met petitioner in the summer of 1977 when petitioner approached him for legal advice regarding an upcoming business deal. In the fall of that year, Mr. Russell went into business as petitioner's partner in various investments relating to computer application programs and oil and gas exploration. Mr. Russell's responsibilities at MBMC included handling petitioner's personal tax matters. He prepared and filed petitioner's 1980 and 1981 Federal income tax returns and represented petitioner before the Internal Revenue Service (the Service) in connection with those returns.3 On April 14, 1983, Mr. Russell prepared and filed an application for an automatic extension of time to file petitioner's 1982 Federal income tax return. He attached petitioner's check in the amount of $360,000, which represented Mr. Russell's estimate of petitioner's 1982 tax liability. Mr. Russell advised petitioner that the extension request had been 2Mr. Russell received his LL.B. from Harvard Law School and his LL.M. in taxation from New York University School of Law. 3He also prepared petitioner's 1978 and 1979 tax returns.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011