Estate of Harvey Feinsmith, Deceased, Betty Feinsmith, Executrix - Page 3




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          about October 5, 1984.  They filed their 1984 return on or about            
          October 17, 1985.  Randy Hall, Inc. (Randy Hall), a corporation             
          in which petitioner was a shareholder, filed its 1982 Federal               
          income tax return for its fiscal year ended January 31, 1983, on            
          April 30, 1983.  Randy Hall filed its 1983 Federal income tax               
          return for its fiscal year ended January 31, 1984, on April 28,             
          1984.                                                                       
               Randy Hall manufactured T-shirts and ladies sportswear.                
          During the subject years, its common stock was owned equally by             
          Mr. Feinsmith, Carl Perry (Mr. Perry), and Donald Rosenthal (Mr.            
          Rosenthal).  Mr. Feinsmith served as its president and production           
          manager.  Mr. Perry served as its secretary/treasurer and                   
          salesman.  Mr. Rosenthal served as its vice president and                   
          designer.  Randy Hall’s shareholders during its fiscal year ended           
          January 31, 1981, were Mr. Perry, Mr. Rosenthal, and Samuel                 
          Mandel (Mr. Mandel).  Mr. Feinsmith replaced Mr. Mandel as a                
          Randy Hall shareholder towards the end of 1982 and began working            
          for Randy Hall at that time.  Mr. Mandel retired at the same                
          time.                                                                       
               During its fiscal years ended January 31, 1981, 1983, and              
          1984, Randy Hall participated in a massive false invoice scheme             
          (the scheme) in which it bought invoices listing falsely that it            
          purchased yarn from various vendors.  The scheme was promoted by            
          Schnejer Zalman Gurary, Nochum Sternberg (Gurary’s son-in-law),             






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