- 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.
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