William and Joan Spears - Page 19

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          football coach.  Four years later he joined the investment firm             
          of Smith, Barney, Harris & Upham (Smith, Barney).  Farrell became           
          a successful retail salesman for Smith, Barney and eventually               
          influenced the investment of approximately $50 million.  In 1982            
          Farrell became a partner at the investment management firm of               
          Spears, Benzak in midtown Manhattan.  Over the next 12 years                
          Spears, Benzak increased the amounts it had under management from           
          approximately $150 million to nearly $3 billion.                            
               On their joint 1982 Federal Income tax return, William and             
          Joan Spears reported gross income from wages, interest,                     
          dividends, State and local tax refunds, and capital gains in                
          excess of $700,000.  On their 1982 return, Vincent and Clotilde             
          Farrell reported gross income from wages, interest, dividends,              
          and State and local tax refunds in excess of $250,000.                      
          Consequently, in the absence of significant deductions or                   
          credits, petitioners in these consolidated cases were subject to            
          payment of Federal income taxes in substantial amounts.                     
               Spears and Farrell are both partners in SAB Associates, a              
          limited partnership initially involved in tax straddle                      
          investments.  During 1981, the tax laws changed and as a                    
          consequence SAB Associates was likely to realize substantial                
          gains.  SAB Associates ceased engaging in tax straddle                      









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