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which substantiates all adjustments reflected on IRS Form
5278 Statement of Income Tax changes attached to your Notice
of Deficiency by June 24, 1985.
Thank you for your cooperation.
Very truly yours,
Frank Pasternak
Co-tenant Operator
The consent form attached to the letter read as follows:
The undersigned hereby desire(s) to contest the attached
Notice of Deficiency and authorize Frank Pasternak or his
representative to file a joint/consolidated petition with
the United States Tax Court for a redetermination of the
deficiency.
The undersigned hereby enclose(s) a copy of his/her
Statutory Notice of Deficiency.
Upon receiving signed consent forms from each of the Pop
Phonomasters participants, Mr. Pasternak forwarded the consent
forms and notices of deficiency to Mr. Young, the attorney. The
participants who responded to the letter also made payments for
instituting litigation in this Court in the form of checks made
payable to Mr. Pasternak. Mr. Pasternak, in turn, deposited the
checks into a bank account he held as agent for Pop Phonomasters
and then issued a check from such account to Mr. Young
representing total payment from all petitioners.
At the hearing on the subject motion, Mrs. Dornbrock
testified that, although she was not aware of the details
surrounding the Pop Phonomasters program, her husband had told
her about his investment in Pop Phonomasters and that she had
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