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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.
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