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joint Federal income tax returns for 1982 and 1983, the years under
consideration.
Petitioner is a medical doctor who has been practicing
medicine for more than 50 years. Over the years, petitioner’s
practice has focused, to a considerable extent, on sports and
exercise medicine.
In 1982, petitioner acquired a 2.83-percent interest
(represented by one partner unit) in Therapeutics CME Group, L.P.,
a Connecticut limited partnership (the partnership), for $17,160.
The stated purpose of the partnership was to acquire by lease and
thereafter exploit a series of video disk master programs on
exercise and sports therapy. The master programs were to be
produced by World Video Corp. in connection with the School of
Continuing Education and the Television Center of Hahnemann Medical
College and Hospital of Philadelphia (Hahnemann). The partnership
was to arrange for the reproduction of the programs on video
cassettes and video disks and thereafter sell them principally to
members of the medical profession for use in satisfying their
continuing medical education requirements.
Petitioner learned about the partnership from B. Roland
Freasier, Jr., petitioner’s friend and a person whom petitioner had
used as an accountant and attorney, and from whom he obtained
investment advice. Freasier arranged for petitioner to meet with
Virgil Williams, the partnership's tax matters partner. Williams
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