Harris Levin and Gayle Levin - Page 3

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          signed the investment documents at the direction of Mr. Levin.              
          Petitioners filed a joint Federal income tax return for 1980,               
          claiming losses of $128,968 arising out of their Schulman                   
          partnerships.  They also claimed a net operating loss carryback             
          to 1979.                                                                    
               In entering into the Schulman partnerships, investors,                 
          including petitioners, had been assured that they would receive             
          legal representation if the Internal Revenue Service (IRS)                  
          challenged their deductions.  Schulman employed Bruce I. Hochman            
          (Hochman) and Martin N. Gelfand (Gelfand) to represent the                  
          investors.  After they were audited, investors sent their                   
          statutory notices of deficiency to Schulman.  Schulman's office             
          prepared petitions to this Court from forms provided by Gelfand.            
          The petitions were sent to Gelfand for signature and were                   
          returned to Schulman's office for filing.  Gelfand's office sent            
          communications concerning the partnerships to Schulman's office             
          for dissemination to the investors.  Few, if any, of the                    
          investors ever met with Gelfand.  Ms. Levin never met Gelfand,              
          and Gelfand had no personal familiarity with petitioners'                   
               Sometime prior to March 1982, an audit of petitioners' 1980            
          tax return was commenced by the IRS.  In March 1982, Mr. Levin              
          executed a Form 2848, Power of Attorney, authorizing Ronald I.              
          Anson (Anson), C.P.A., to act with respect to petitioners' 1980             

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