- 9 - reasonable. Both Burstein and Ulanoff held investments in plastics recycling transactions. The offering memorandum disclosed that Burstein was a client and business associate of PI’s corporate counsel. Petitioner is an attorney who practiced real estate law in a New York firm during the year in issue. During the course of a real estate transaction in 1979, petitioner was impressed with his client’s financial adviser, Harris W. Freedman (Freedman). After the real estate transaction was completed, petitioner retained Freedman’s accounting firm, H.W. Freedman & Co., to prepare his annual tax returns. In addition to being the named partner in an accounting firm, Freedman was the president of F&G. In 1982, Freedman sent petitioner a private placement memorandum for Foam. Petitioner has no education or work experience in plastics recycling or plastics materials. Petitioner discussed the investment with Freedman. He read the offering memorandum and reviewed it with Jake Jacobson (Jacobson), his tax return preparer from H.W. Freedman & Co. He also discussed the transaction with one of the associates in the tax department of petitioner’s law firm. The associate told petitioner that he “might have a supportable tax position”. After reviewing the offering memorandum with petitioner, Jacobson came to petitioner’s office and told him that he hadPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011