Jordon Jay Fingar - Page 4

                                        - 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

Last modified: May 25, 2011