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administration. After graduating from Harvard, petitioner worked
in the real estate business. In 1982, he began trading
securities. Before 1987, petitioner either explored the
possibility of taking over control, or attempted to take over
control, of several publicly traded companies, including
Hammermill Paper Co. (Hammermill), Armco, Cluett Peabody, H.H.
Robertson, and Syntex Corp.
In 1986, petitioner and Earl and Billy Mack (the Macks)
formed a partnership, Bilzerian & Mack Associates (Bilzerian &
Mack), for the purpose of launching a takeover of Hammermill.
Petitioner was a general partner of Bilzerian & Mack, and he
signed the partnership return for 1986 on March 23, 1987. Mack
Asset Co. and Bilzerian Investors, two partnerships, were
reported on Bilzerian & Mack’s 1986 Form 1065, U.S. Partnership
Return of Income, as other general partners. Petitioner was
involved in Bilzerian Investors and another partnership named
Bilzerian Ventures. Although Hammermill was eventually acquired
by International Paper Co. in August of 1986, petitioner realized
substantial gains in 1986 through Bilzerian & Mack, Bilzerian
Investors, and Bilzerian Ventures from the purchase and sale of
Hammermill stock.
During 1986, petitioner also maintained interests in South
Bay Fashion Center and South Bay Fashion One, two partnerships,
and various other entities.
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