- 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