- 9 - 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 hadPage: 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