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findings of fact herein are based upon our review of the record,
in particular petitioner's pleadings and the deemed admissions.
Petitioner resided in Boston, Massachusetts, when his
petition was filed. Petitioner practiced law during the 1970's
in New York and Massachusetts with Paul Garfinkle (Garfinkle) and
others. He and Garfinkle organized and promoted tax-oriented
limited partnerships during the 1970's, including shelters
relating to movies, master recordings, real estate, and mining.
These partnerships fall into two distinct subgroups that we
collectively refer to as the "S-J partnerships"3 and the "Real
Estate partnerships."4
Petitioner prepared and filed Federal income tax returns for
the taxable years 1975, 1976, and 1979-82, but failed to file
returns for 1977 and 1978. On May 31, 1984, petitioner filed
documents with the Internal Revenue Service that purported to be
Forms 1040, U.S. Individual Income Tax Returns for 1977 and 1978.
These documents were not valid returns; they contained false
statements concerning petitioner's liabilities for 1977 and 1978,
and they were filed to mislead the Internal Revenue Service.
3 The S-J partnerships include: S-J Mineral Associates, L.P.;
S-J Mineral Associates II, L.P.; S-J Mineral Associates III,
L.P.; INAS Associates, L.P. (an acronym for International
Associates, L.P.); and G & O Associates.
4 The Real Estate partnerships include: That Certain
Encounter; Tudor Associates, Ltd. I; Tudor Associates, Ltd. II;
Applewood Associates, Ltd.; Harrison Associates, Ltd.; O and G
Associates, Ltd.; and Providence Place Associates, Ltd.
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