- 8 - instructions, the exclusive right and duty to conduct the operations of the Pop Phonomasters program. More specifically, Mr. Pasternak was authorized to maintain books and records and to pay all ordinary and necessary expenditures without consulting other participants. As Pop Phonomasters participants began receiving notices of deficiency regarding their investments, some of them contacted Mr. Pasternak about the matter. In response to their inquiries, and in his capacity as CTO, Mr. Pasternak mailed a form letter to each of the Pop Phonomasters participants regarding the notices of deficiency received by them. The form letter was drafted by Mr. Young's law firm; however, the letters were signed by Mr. Pasternak and were printed on "Phonorecords Phonomaster Leasing" letterhead and stated: Dear Co-tenant: As you are aware, the Internal Revenue Service has been conducting an investigation into the tax liabilities of certain co-tenants participation in Pop Phonomaster Leasing Program. We were recently informed that certain co- tenants have received Statutory Notices of Deficiency. It appears that certain of these investigations by the IRS involve substantial and controlling common questions of law or fact. Accordingly, if you wish to join in a consolidated effort (joint Tax Court Petition) return an executed copy of the enclosed Consent Form by June 24, 1985 since your petition will very probably have to be filed with the United States Tax Court, Washington, D.C., by July 11, 1985. To help me and/or my representative prepare the petition, promptly deliver to me all available informationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011