- 3 -
A. Frederick Greenberg.3 Respondent began an examination of the
partnership at some point in the mid-1980's as part of a national
project focusing on the various partnerships of the Greenberg
Brothers (the Greenberg Brothers project). Richard M. Greenberg,
who was then the tax matters partner (TMP) of the partnership,
retained Peter L. Faber (Mr. Faber) to represent the partners at
the partnership level during respondent's examination.4 Mr.
Faber also represented the partners at the partnership level upon
filing the petitions in the cases at docket Nos. 623-92, 13014-
92, and 15641-92.
3
On its partnership returns for the years in issue,
First Blood claimed loss deductions arising from the alleged
purchase of the film "First Blood" starring Sylvester Stallone.
We note that whether the partnership obtained the benefits and
burdens of ownership in the film is not here at issue, but has
formed the basis for considerable securities litigation. See,
e.g., Block v. First Blood Associates, 988 F.2d 344, 347 (2d Cir.
1993), and cases cited therein.
4
Richard M. Greenberg became disqualified from acting as
the TMP when an involuntary petition in bankruptcy was filed
against him in January 1994. See sec. 6231(c); sec.
301.6231(a)(7)-1(l)(1)(iv), Proced. & Admin. Regs.; sec.
301.6231(c)-7T, Temporary Proced. & Admin. Regs., 52 Fed. Reg.
6793 (Mar. 5, 1987).
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