Gary Friedmann - Page 5




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             petitioner but should have been reported by Friedmann                    
             Management Corp.  Id. at 511.                                            
                  Petitioner also prosecuted a case in this Court                     
             involving adjustments to his joint return for 1988 that                  
             was settled before trial pursuant to an agreement of the                 
             parties.  Lastly, in 1996, he sued the United States to                  
             quash two Internal Revenue Service summonses, one of which               
             demanded all documents and records regarding petitioner's                
             assets, liabilities, and accounts for purposes of preparing              
             a "collection information statement", and the other of                   
             which sought all books, records, documents, and receipts                 
             for income from all sources for purposes of preparing                    
             Federal income tax returns for 1991 through and including                
             1995 that had not been filed by petitioner.  Friedmann v.                
             United States, 79 AFTR 2d 97-895 (D.N.J. 1997).  In that                 
             case, the court granted the Government's motion to dismiss               
             petitioner's complaint.  Id.                                             
                  Petitioner failed to timely file his individual                     
             Federal income tax returns for tax years 1989 through 1995.              
             He filed delinquent returns for 1989 and 1990, the years at              
             issue, as discussed below, but he had not yet filed his                  
             returns for tax years 1991 through 1995 at the time this                 
             case was tried.                                                          








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