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D. Petitioners and Their Introduction to the Partnership
Transactions
Petitioner Richard E. Snyder (Snyder) resided in Cross
River, New York, when his petition was filed. He is a graduate
of Tufts University with a B.A. in economics. Snyder has enjoyed
a very successful career with the publishing company Simon &
Schuster, Inc. (Simon & Schuster). He worked for Simon &
Schuster for 33 years, up until the midpoint of 1994. For about
the latter 20 of those years, including the taxable years in
issue, he was chairman and chief executive officer (CEO) of Simon
& Schuster. As chairman and CEO, he was responsible for all of
the policies and practices of the corporation, all of its mergers
and acquisitions, and all personnel policies and strategic
planning. Snyder oversaw roughly 75 acquisitions on behalf of
Simon & Schuster, involving sums ranging from less than $1
million to $800 million.
Petitioner Ronald Busch (Busch) died prior to trial. He and
his wife Rochelle resided in New York, New York, at the time
their petition was filed. During 1982 Busch was the president
and publisher of Pocket Books, the paperback division of Simon &
Schuster.
On his 1981 and 1982 Federal income tax returns, Snyder
reported gross income from wages, interest, dividends, State and
local tax refunds, and capital gains in excess of $700,000 and
$800,000, respectively. During the years in issue, petitioner
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