Gary Friedmann - Page 36




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                       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 York                        





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