- 10 - 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 consideredPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011