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receive any other compensation for the sale of interests in the
partnership.
Petralia also was a limited partner in Mount Mercy. As a
limited partner, Petralia had an interest in seeing that the
partnership would be fully subscribed. According to Petralia,
one of the special limited partners could have brought in enough
New York City area investors to fully subscribe the partnership.
Petralia had to fight to get available units for the Rochester
investors he would be bringing into the partnership.
Petralia discussed the Mount Mercy partnership with
petitioner and other investors. Petralia did not offer any
significant opinion on the validity of the contemplated
charitable contribution deductions beyond what was stated in the
Memorandum. Petitioner was aware of Petralia's relationship with
Mount Mercy at the time of these discussions. Petralia did not
charge petitioner for legal or tax advice pertaining to his
discussions regarding Mount Mercy, because according to Petralia,
that would have constituted a conflict of interest with his work
for Mount Mercy.
Petralia stated he had done legal work for petitioner and
his partner. The parties stipulated that Petralia was outside
counsel for petitioner's business, Flexseal Packaging, providing
a wide range of legal services to the business and its principals
since 1980.
It is obvious from the above that Petralia considered
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