Peter and Ursula Reimann, et al. - Page 13

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          investment.  Reimann purportedly relied on Bachmann because his             
          father's company relied on and trusted Bachmann.                            
               Although Reimann read the Scarborough offering memorandum              
          and the appended evaluations, he did not focus on or pay heed to            
          the risks and caveats raised therein.  Reimann noticed the                  
          warning that there might be an IRS audit, but claims that he did            
          not notice the warning that the IRS might challenge the value of            
          the recyclers.  Reimann did not conduct an independent valuation            
          of the recyclers, nor did he determine if the recyclers had been            
          placed with end-users prior to his making the investment.  He did           
          nothing more than ask Bachmann some questions about the offering            
          memorandum.  Reimann claims he did not know whether Bachmann,               
          Schwartz was being compensated in any manner with respect to the            
          Scarborough partnership investment, nor did he ask if they were             
          receiving compensation of any sort.                                         
          2.  Edward Brodie and Estate of Alana Brodie, Docket No. 35003-86           
               Petitioners Edward Brodie and his wife, Alana, resided in              
          Englewood Cliffs, New Jersey, at the time their petition was                
          filed.  During 1981, Edward Brodie (Brodie) was a salesman at his           
          family's business, M & M Luggage Co., Inc. (M & M Luggage).                 
          Alana Brodie was not employed outside the home.  On their 1981              
          Federal income tax return, the Brodies reported total income from           
          wages, interest, dividends, capital gains, and other sources in             
          the amount of $123,308.  Consequently, in the absence of                    
          significant deductions or credits, they were subject to payment             
          of Federal income taxes in substantial amounts.                             



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