-3- 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. WilliamsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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