- 3 - Beginning in 1979, petitioner spent nearly 10 years working for tax shelter promoters. From 1979 through July of 1980, petitioner worked for Mr. Margolis, writing opinion letters, providing tax advice, and regularly meeting with representatives responsible for the foreign corporations used in Mr. Margolis' tax shelters. In July of 1980, petitioner went to work for the Schulman Management Co., a company that promoted tax shelters and that was wholly owned by Gerald Schulman. Petitioner worked for Mr. Schulman for almost 8 years and became thoroughly familiar with the tax shelter transactions Mr. Schulman promoted. Petitioner prepared opinion letters and private placement circulars concerning these transactions. In addition, petitioner traveled to the Caribbean and Panama to meet with representatives of foreign corporations involved in Mr. Schulman's tax shelters. Mr. Schulman organized, promoted, and syndicated approximately 478 similarly structured limited partnerships and served as the general partner of each of them. Two of these partnerships, Woodchuck, Ltd. (Woodchuck), and Wolverine, Ltd. (Wolverine), were formed while petitioner was employed by Mr. Schulman. During 1982 and 1983, Woodchuck sold 33 limited partnership interests, raising $2,700,000 in capital contributions. Petitioner contributed $121,010 for a limited partnership interest in Woodchuck and $96,790 for a limited partnership interest in Wolverine.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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