- 4 - Number 1, and Friedmann Investors Number 2. It appears that the business of these partnerships involved investments in real estate. A number of clients of petitioner's Schedule C business, including some clients on behalf of whom the expenditures at issue in this case were allegedly made, were investors in one or more of these partnerships. Petitioner was also the sole owner and employee of Friedmann Management Corp., which allegedly provided management services to the partnerships. In addition to the instant case, petitioner prosecuted a suit in District Court for refund of taxes paid with respect to his joint return for 1987. Friedmann v. United States, 107 F. Supp. 2d 502 (D.N.J. 2000). In that case, the court granted the Government's motion to dismiss one count of the complaint on the ground that it raised issues that had not been set forth in the claim for refund, and the court granted summary judgment as to the other count of the complaint, involving certain consulting fees that petitioner claimed as an expense deduction on his Schedule C, Profit or Loss From Business. According to the court, the consulting fees were not deductible because petitioner had admitted in his complaint that the consulting fees were not income to, nor a business expense incurred by,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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