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had agreed to an injunction that barred them from promoting tax
shelters. On August 15, 1983, Schluter received and reviewed a
letter from Hamilton’s TMP that discussed the WSJ article.
Sometime thereafter, petitioners contacted Schluter regarding the
article. Schluter told petitioners that Hamilton’s TMP had sent
him a letter discussing the WSJ article and that the letter
addressed his concerns.
In 1984, petitioners contacted Schluter regarding IRS
correspondence they had received, which stated that deductions
and credits relating to Hamilton were not allowable and that the
IRS planned to audit their returns. On September 11, 1984, the
IRS began an audit of Hamilton by contacting Hamilton’s TMP.
Thereafter, Hamilton’s TMP kept Schluter and other Hamilton
investors advised of all developments regarding the IRS audit.
E. Thornsjo
After his graduation from the University of Minnesota with a
bachelor of arts degree and military service and 2 years of
graduate school education, Thornsjo began working for Honeywell
as a manager in the avionics field. Thornsjo worked for
Honeywell for 35 years. Immediately before his retirement,
Thornsjo was the director of Honeywell’s automatic test equipment
business, a $145 million business. Previously Thornsjo had been
employed as the general director of Honeywell’s Apollo program.
Thornsjo’s business experience is reflected by his
accomplishments at Honeywell in the area of operational
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