Davenport Recycling Associates, Sam Winer, Tax Matters Partner - Page 11

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          until he "received a bill from the IRS."  Karras testified that             
          he "couldn't believe that the case was over with and nobody had             
          told us anything."  In the end, Karras was "bowled over" by the             
          size of the tax liability that had resulted from his "simple                
          $50,000 investment."                                                        
          E.  The Winer Section 7408 Injunction Proceeding                            
               In 1984, Winer and Winer Development Corp. were identified             
          by respondent as persons who had violated section 6700 by                   
          promoting or selling partnerships or other arrangements that                
          included gross valuation overstatements.  Subsequently,                     
          respondent issued prefiling notification letters to Winer and the           
          notice partners of Davenport, including participants, regarding             
          Davenport on April 14, 1984.  These letters stated that the                 
          Internal Revenue Service (IRS) planned to review the 1982 and               
          1983 tax returns of each investor in Davenport for claimed tax              
          deductions and credits resulting from an investment in the                  
          partnership, which had been identified as a tax shelter.  The               
          letters indicated that the IRS did not believe the purported tax            
          deductions and/or credits were allowable and that if such tax               
          deductions and/or credits had been claimed by the investor, his             
          or her return would be audited.  The investor also was provided             
          an opportunity to file an amended return.                                   
               On April 13, 1984, respondent, through the Office of                   
          District Counsel in Jacksonville, authorized the U.S. Department            
          of Justice (DOJ) to seek injunctions under section 7408 against             




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