Gary Friedmann - Page 32




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             subject payments to clients, to the Internal Revenue                     
             Service, or to State tax authorities in order to resolve                 
             "tax problems that was [sic] due to an error or omission                 
             made by the Petitioner."  According to petitioner:  "These               
             [payments] were for tax services that I performed that                   
             there was some kind of problem with."  According to                      
             petitioner, in each case after "negotiations with client(s)              
             and once the Petitioner and the client came to an oral                   
             agreement that the Petitioner would pay the tax bill", "the              
             direct payment was made to fully settle the legal dispute                
             between the Petitioner and his client."  Petitioner asserts              
             that "he did not carry professional malpractice insurance",              
             and he orally agreed with his clients to make each of the                
             payments "to avoid litigation and to retain customers."                  
             Furthermore, according to petitioner, each of the direct                 
             payments was made "to resolve a tax problems [sic] that                  
             was due to an error or omission made by the petitioner."                 
             Petitioner states:  "There was no connection between the                 
             'direct payment' and billing", except in the case of the                 
             reimbursed payments, discussed below.                                    
                  To prove the nature of the subject direct payments,                 
             petitioner relies on his own testimony, copies of                        
             canceled checks or other evidence of payment, such as wire               
             transfers, and in several instances, copies of the bills                 






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Last modified: May 25, 2011