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the findings of facts to the extent necessary to address the
issues identified above. For a more detailed explanation of the
Barrister partnerships, see the cases cited above.
Some of the facts were stipulated, and those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioners'
legal residence was Santa Rosa, California.
The promoter of the Barrister partnerships, and of the
transactions involved herein, was an individual named Irving
Cohen (Cohen). Cohen organized and controlled an entity named
Universal Publishing Resources Ltd. (Universal).3 At Cohen's
request, in 1981, Paul F. Belloff (Belloff) and Robert Gold
(Gold) formed Barrister Associates (Barrister), a New York
general partnership. Belloff and Gold each held a 50-percent
interest in Barrister.
Between 1981 and 1983, Barrister organized and was the
general partner of the Barrister partnerships. Barrister
organized 35 limited partnerships in 1982, collectively named the
Barrister Equipment Associates Series 80 through 114, and 300.
In 1983, Barrister organized 60 limited partnerships,
collectively named the Barrister Equipment Associates Series 115
3
The Madison Library, Inc. (Madison), a corporation, was
owned, directly or indirectly, for the benefit of Cohen's
children. In the 1980's Madison formed a subsidiary, Geoffrey
Townsend, Ltd. (Townsend). Universal was a subsidiary of
Townsend, and Cohen was Universal's president.
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