Sheldon M. Sisson - Page 3

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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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