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and a law degree from Yale Law School in 1961. After service in
the Army, Addington moved to New York City and was employed in
the trust department of the Morgan Guaranty Trust Company.
Approximately 4 or 5 years later, in 1967, he joined the law firm
of Breed, Abbott & Morgan and practiced in their trusts and
estates department. In 1973 he joined the law firm of Sann &
Howe, and he became a partner in that firm the following year.
Addington specializes in estate planning and administration.
In 1981, Addington acquired an indirect, limited partnership
interest in Empire with a $25,000 investment in S&H Empire, and
an indirect limited partnership interest in Plymouth with a
$6,520 investment in Plymouth Partners. In 1982, he acquired an
indirect, limited partnership interest in Foam with a $25,000
investment in Jabrilach Recycling.
As a result of his indirect investments in Empire and
Plymouth, on his 1981 Federal income tax return Addington claimed
operating losses in the respective amounts of $18,013 and $4,454,
and investment tax and business energy credits totaling $53,416.9
Addington also claimed operating losses from Empire and Plymouth
on his 1982 return in the respective amounts of $406 and $141.
As a result of his indirect investment in Foam, on his 1982
return Addington claimed an operating loss in the amount of
9 The notice of deficiency in docket No. 21519-88 indicates
that of the $53,416 in credits, $43,080 derived from Empire
($21,876 in investment tax credits and $21,204 in business energy
credits) and $10,336 derived from Plymouth ($5,158 in investment
tax and business energy credits each).
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