- 21 - included a description of the Clearwater transaction, and discussed that with Wilson by telephone. Paulson served as Wilson's offeree representative as to EI, and he discussed the investment with Wilson by telephone. Wilson explained that the conference was by telephone since he was in New Orleans and Paulson was in Indiana in 1981. As noted above, Morton Efron was the general partner in EI and had a substantial financial interest in the partnership and in its management. Wayne Paulson had introduced Wilson to Efron. See Paulson v. Commissioner, T.C. Memo. 1995-387, concerning Wayne Paulson's brother, as to the relationship between Efron and Paulson. Efron was also Sorey's attorney and agent for his football contracts in 1981. Efron had represented Sorey since he began playing professional football in 1975. In 1981, Sorey was 26 years old. Sorey testified that Efron was involved in all of his business decisions. Sorey learned of EI through the original offering memorandum, which Efron sent to him. Prior to 1981, Sorey's only investments were real estate investments in which Efron was involved and "some land deals" with his family. Sorey's offeree representative with respect to EI was Norman Diamond, his accountant, who had been introduced to Sorey early in his career by Efron. The record does not indicate that Diamond made any extensive investigation of EI for Sorey's benefit. Sorey also discussed EI with Cassaday, the banker who,Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011