- 3 -
certified public accountants licensed to practice in New York,
and partners in H. W. Freedman & Co. In June 1984, Jacobson
purchased Freedman’s interest in H. W. Freedman & Co.
In 1983, the IRS determined that Roberts had violated
section 6700 by promoting and selling limited partnership
interests in plastics recycling partnerships (the partnerships).
Pursuant to section 7408, on August 8, 1983, the United States
filed a civil complaint in the U.S. District Court for the
District of Massachusetts seeking an injunction against Roberts
and other promoters of the partnerships. On the same day, in
accordance with a consent agreement signed by Roberts on August
4, 1983, the court issued a permanent injunction against Roberts
and other promoters to prevent them from further organizing,
promoting, or selling abusive tax shelters. See Announcement of
Injunctions Under Section 7408 of the Code, 1985-1 C.B. 671.
Roberts moved to Paris, France, sometime during 1984; apparently
he has continued to live there ever since. In January 1985,
respondent assessed a section 6700 civil penalty of $205,000
against Roberts for his role in the promotion of the
partnerships.
The examination of Madison’s 1982 tax year began sometime in
1984. On April 2, 1984, Roberts, Freedman, and Jacobson signed a
Form 2848, Power of Attorney and Declaration of Representative,
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011