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concerns about the return of his investment. In a letter dated
May 29, 1984, in response to a conversation held on May 22, the
general partner of MSA Jules Klar (Klar), reassured petitioner
that the Internal Revenue Service had not audited the partnership
returns to date and he had no indication that such a challenge
would be forthcoming.
In July 1984, Andrews wrote a letter to Samuel Harding in
reference to his introduction to Geldbach. Andrews stated:
You asked me how I got acquainted with Arthur Geldbach. My
memory will, perhaps, be faulty with specific details but I
remember the gist of the matter.
In the late spring or early summer of 1984, Art and I met
during a backyard party at the home of a mutual friend.* * *
* * * * *
The next week, we met at the Port Tack Restaurant [to
discuss the investments he had presented to you]. I told
him I was unable to judge the quality of the partnership
investments but that I had serious misgivings about [MSA].
I also told him that you and [petitioner] were less than
happy for me to direct them to staple checks to their 1983
tax return extension requests. He said that [MSA] was an
excellent "tax shelter" and he owned an interest in it also.
I told Art that until the IRS examined, neither of us would
ever know for sure. Art said he was proud of the investments
he had sold you and [petitioner]. He said he was confident
they would perform well both as to investment quality and
tax advantages, and that he had done a good job in selecting
them for you. I interpreted these remarks as meaning he had
performed "due diligence" in reviewing their quality.
As to the fact that you had to pay tax for 1983, he said
your tax was extremely small compared to your income. My
response was that $60,000 was still a huge surprise to you
when you had expected none. Art said you were unrealistic
to interpret Mr. Barney's opinion to mean no tax at all.
Since that lunch, Art and I have had no contact. In fact, we
avoid each other when circumstances put us in the same room.
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