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Cooper trust. Rita Cooper was a member of the Saligman family.
In April 1979, petitioner began his examination of the 1977 Rita
Cooper trust return and the 1977 tax return of the Harvey
Saligman trust. Petitioner expanded his examination to include
the 1978 tax returns for the two trusts. Neither the Rita Cooper
Trust, nor the Harvey Saligman Trust, was a partner in the Cynwyd
Investments partnership. The trusts did hold interests in
various partnerships in which Cynwyd Investments held an
interest, and which were a part of the Cynwyd Group.
Petitioner notified Toll that he was examining the two trust
returns. Petitioner and Toll entered into discussions about the
audit. The outcome of those discussions was that Toll would pay
petitioner $105,000 to (1) extend his examination to include the
1977 and 1978 tax returns of various members of the Cynwyd Group,
including, among others, the returns of Cynwyd Investments,
Saligman Capital, and the individual returns of the Saligman and
Cravitz family members, and (2) make sure that the examinations
resulted in favorable tax treatment by overlooking various tax
adjustments that otherwise would have been required. Toll agreed
to pay petitioner the $105,000 in periodic installments upon
Toll’s receipt of IRS clearance letters from the IRS review
department.
Suval’s Review
From the beginning of 1979 through August 1980, Irving Suval
(Suval) was the assistant review chief of the Philadelphia IRS
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