- 35 -
Feinstein also prepared all of petitioners' tax returns. Alter
explained his and Feinstein's limited involvement in petitioners'
investment activity as follows:
The clients in almost all cases when they had an
investment proposal presented to them asked for our
opinion as to its validity and merit, and to the extent
that we were able to give advice, we gave advice.
* * * * * * *
Of course you should understand that many of these
clients were high income performers. They had
presented to them very frequently from other performers
proposals that involved * * * tax shelters, and they
brought them into our office for review.
Under my review or at my direction, Mr. Feinstein
reviewed these proposals and they involved all sorts of
* * * tax shelters and invariably these proposals were
rejected as being without merit. [Emphasis added.]
Feinstein explained that petitioners "would come in and say, I
spoke with so-and-so, he's got a terrific thing that was going to
make a lot of money or something and why don't you find out
something about it and let us know--let me know what you find
out."
Alter mentioned a few investments to petitioners for their
consideration, such as the Plastics Recycling transactions. He
did not, however, recommend that petitioners invest in the
Partnerships. Asked if, "in connection with the making of this
investment yourself, and in recommending" the investment to his
clients, he earned a commission, Alter replied: "No, I did not,
and I would like to correct your use of the word 'recommend.' I
told them I was going into it and it seemed sound, and if they
Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 NextLast modified: May 25, 2011