Oceanic Leasing, Douglas F. Spaulding, Tax Matters Partner - Page 13

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          whether Arthur and Susan Willner were "persons holding an                   
          interest in such entity."                                                   
               The evidence supports a finding that Willner was a person              
          holding an interest in the entity that is the subject of this               
          proceeding.  He claimed tax benefits on the assumption that a               
          return was filed for the partnerships in which he invested,                 
          bearing the single EIN 94-2870681; he received cash payments from           
          a single bank account with respect to the partnerships in which             
          he invested; he acquiesced in Hardin's total control of all                 
          entity business with knowledge that Hardin was handling as a unit           
          what were identified as multiple partnerships; he regarded                  
          himself as the beneficiary of a class action that treated the               
          superficially separate partnerships as a single entity; and he              
          did not raise his claim in this action until he saw that the                
          action would neither lead to a determination in favor of the                
          partnership nor a settlement that would benefit him.  The nexus             
          between his claims of partnership losses and credit and the                 
          entity that is the subject of this proceeding exists.                       
               By contrast, there is no evidence that separate partnerships           
          known as Oceanic Leasing VI or Oceanic Leasing XXXV ever engaged            
          in any activity other than the fraudulent leasing transactions              
          engaged in by Hardin in the name of Oceanic Leasing.  Willner did           
          not comply with the terms of the agreements on which he relies.             







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