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for Zobrist. Matthias and Berg left Zobrist in 1988 to form
their own law firm, Matthias & Berg. Matthias became lead
counsel in the test case for the Manhattan group around 1986.
Zobrist, and later Matthias & Berg, represented more than 4,000
limited partners. Zobrist and Matthias & Berg filed several
petitions for most of the limited partners that they represented.
The two firms filed more than 14,000 petitions for limited
partners.
The following typically occurred when Matthias & Berg
prepared petitions for Manhattan limited partners: (1) The firm
received a letter with a copy of a notice of deficiency from the
limited partner, or an accountant or other attorney; (2) the
paralegals prepared petitions on behalf of anyone named in the
notice of deficiency; (3) Matthias or Berg reviewed and signed
the petition; (4) the paralegals sent a transmittal letter to the
limited partner with a copy of the petition; (5) the paralegals
placed copies of any correspondence in the client’s case file;
and (6) the limited partner paid the firm a $120 fee for each
petition filed.
C. The Notices of Deficiency and Petitions in These Cases
1. Tax Years 1981 and 1982 (Docket No. 32146-86)
Petitioner filed his income tax return for 1981 on December
31, 1982, and for 1982 on January 2, 1984. Respondent mailed a
notice of deficiency for tax years 1981 and 1982 to petitioner on
May 15, 1986, at 1 Lily Pond Court, Rockville, Maryland, his last
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