Estate of Jack L. Bradley, Deceased, John S. Bradley, Successor Executor, C.T.A. - Page 13

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          1987.  The amount of recourse debt which decedent was required to           
          assume totaled $923,630.                                                    
               Decedent met Robert Michaels (Mr. Michaels) in the early               
          1980's.  Mr. Michaels was a certified public accountant,                    
          practicing income tax and general accounting since 1969, worked             
          in an accounting firm, and directed staff.                                  
               Mr. Michaels learned of the partnership from a client, then            
          told decedent about it.  Decedent consulted with Mr. Michaels               
          concerning the investment in the partnership.  Mr. Michaels                 
          reviewed the POM, including the opinion letter; he also was of              
          the opinion that a partner would be at-risk for the amount of               
          partnership debt which a partner was required to assume.                    
               Mr. Michaels consulted with decedent's tax counsel, David              
          Weinstein (Mr. Weinstein), about the investment.  Based                     
          on this consultation with Mr. Weinstein, the opinion letter in              
          the POM, and his own analysis, Mr. Michaels approved the                    
          investment, which decedent then made.                                       
               Mr. Michaels prepared for decedent and Mrs. Bradley joint              
          Federal income tax returns for the taxable years which included             
          the deductions at issue, 1984, 1985, and 1986.                              
               Procedural Background                                                  
               Decedent filed Form 1045 (regarding loss carrybacks to                 
          previous years) for the taxable year 1985 on or before                      
          September 26, 1986, and filed Form 1045 for the 1986 taxable year           
          on or before October 5, 1987.  Respondent issued a notice of                




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