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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'
situation.
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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