- 7 - I guess it would be awkward for us to talk about anything, including the weather. Sam, I hope this limited amount of information has some usefulness for you and [petitioner]. Frankly, I never dreamed four years ago that I would need to reconstruct my slight involvement with a "peripheral" fellow being. [Emphasis added.] In August 1984, Gersten, Savage, Kaplowitz & Simensky (Gersten), the law firm representing the partnership, wrote petitioner and demanded the second payment of $61,200. Gersten explained that failure to pay would result in a forfeiture of petitioner's partnership interest and a loss of all tax advantages stemming from MSA in 1984. Petitioner assured Gersten that payment was forthcoming but that it was made with "great reluctance" and that it should "not be construed as a waiver of any claims" which may arise from his investment in MSA.4 In October 1984, petitioners filed their 1983 joint Federal income tax return, wherein they claimed an ordinary loss of $35,539 and an investment tax credit of $79,441 relating to their investment in MSA. The tax credit was calculated using the unadjusted basis ($993,014) of the tapes as reported by MSA on the Schedule K-1. Petitioner also claimed carryback credits for 4 In 1985, petitioner filed suit against Geldbach and Klar, and joined in a suit against McGraw-Hill allegedly for preparation of a fraudulent appraisal.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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