Madison Recycling Associates, et al. - Page 3




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          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,             








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