- 4 - years in issue. We hold he is. (7) Whether pursuant to section 6653(a) petitioner is liable for additions to tax for negligence or intentional disregard of rules and regulations for the taxable years in issue. We hold he is. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulated facts and the accompanying exhibits3 are incorporated into our findings by this reference. At the time the petition in this case was filed, petitioner resided in Surfside, Florida. Petitioner During 1979, petitioner was a real estate attorney and partner at the law firm of Robinson, Silverman, Pearce, Aronsohn, Sand & Berman (Robinson Silverman or the firm) in New York City. While at Robinson Silverman, petitioner began working on transactions of the Bank of New York (the bank), one of the firm's larger and more active clients. At that time, petitioner was representing the bank in negotiating and closing multi- million dollar construction loans for large hotels, condominiums, and office buildings all over the country. Robinson Silverman was not the only firm representing the bank during 1979. Robert Greenbaum (Greenbaum), a partner at 3 At trial, petitioner offered Exs. 11, 12, 13, 14, 86, 89, and 90 into evidence. Respondent objected on the grounds of relevancy. Upon consideration, we find that the exhibits fail to address the issues in the instant case. Accordingly, respondent's objections are sustained.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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