- 36 - Well, if these things were not resolved amicably, it could have been a divisive matter, which would have-–could have led to litigation, as I said, I didn't have malpractice insurance, and also, a loss of clients and client good will. That's my rationale for paying them. In effect, petitioner states that the subject payments were made "to resolve older matters probably pertaining to years '82 to '84". Petitioner gives no explanation of the matters that were resolved. Petitioner's testimony concerning the payments made on behalf of his parents similarly fails to describe the nature of those payments. Petitioner's testimony is as follows: The next check is 50-–is 22-3, which was paid directly to the Internal Revenue Service on behalf of my father, Eric Friedmann. It's actually my parents, Eric and Phyllis Friedmann, for a tax problem. I would just note that my parents were clients and in the year 1989, they paid me taxable fees of $7,374. When I say they paid me fees, these are all reflected in my income schedules that were reconstructed, that are found in files 20-J for 1989 and 21-J for 1990. And these have been accepted by the Internal Revenue Service for purpose-–as noted in the audit work papers, although they don't tie in precisely to the income per the tax return. The next item has to do with Eric Friedmann, who is, again, my father. These had to do with items 15-A2, A3, A4, and A10. The first one being payment directly to New York State on behalf of him of $470.29. The next one is 15-A3, had to do with payments directly to New York State in the amount of $114.70. The next one is 15-A4, which is payment directly to New YorkPage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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