George M. Osserman - Page 6

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               The promotion of the S-J partnerships was a fraudulent tax             
          shelter promotion.  In a class action, the District Court entered           
          a conclusion of law that petitioner and Garfinkle engaged in                
          acts, practices, and a course of business that operated as a                
          fraud and deceit upon purchasers of limited partnership interests           
          in the S-J partnerships.5  Petitioner has previously pled guilty            
          to crimes of fraud and deceit arising from the S-J partnerships,            
          including:  (1) Mail fraud; (2) aiding, assisting, and advising             
          in the preparation of an individual income tax return which was             
          fraudulent as to material fact; and (3) willfully and knowingly             
          conspiring to devise a scheme to defraud and to obtain money from           
          the Internal Revenue Service by means of false representations.             
               For the years 1975 through and including 1982, petitioner              
          failed to maintain complete and adequate books and records of his           
          income-producing activities, and he failed to cooperate with                
          respondent's agents in submitting his books and records to them             
          for examination.  In addition, petitioner fraudulently and with             
          intent to evade tax made or caused to be made false and                     
          misleading representations to agents of respondent during their             
          investigation of entities with which petitioner was associated              
          and for which he claimed deductions on his returns for the                  
          taxable years 1974-76 and 1979-81.                                          

          5    The class action referred to above was brought by investors            
          in the S-J partnerships.  Den Haene v. Inas Associates, L.P., No.           
          78 civ. 4360 (CES) (S.D.N.Y., filed Nov. 2, 1984).                          





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