- 4 - Mr. Schulman promoted the partnerships by representing that each limited partnership interest would be entitled to an interest deduction in the first year equal to the partner's cash capital contributions. The purported interest deductions for the first year were generated through a circular transfer of funds among several entities, including foreign entities in Panama and the Netherlands Antilles. The transactions occurred between December of 1982 and December of 1983. On August 22, 1983, the IRS and Mr. Schulman executed a preliminary agreement entitled "SETTLEMENT PLAN AGREEMENT". The agreement's "RECITALS" section stated: 2.1 IRS is presently auditing SCHULMAN'S individual tax returns (IRS Form 1040) for the years 1977 through 1982. Additionally, IRS intends to audit SCHULMAN'S 1983 individual tax return (IRS Form 1040). * * * * * * * 2.4 IRS and SCHULMAN desire to amicably settle all questions relating to SCHULMAN'S individual tax returns and the deductions taken by the investors in connection with their investment in the SCHULMAN Partnerships. * * * 2.5 This document is intended to be an agreement in principle establishing the concepts upon which a formal settlement agreement will be drafted. Both the IRS and SCHULMAN shall exercise the utmost good faith in attempting to achieve the final settlement of the matters described herein. Nevertheless, SCHULMAN and the IRS acknowledge that the concepts established hereunder may result in unforeseen consequences which may render settlement impossible.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011