Jeffrey H. Weitzman - Page 9




                                        - 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 had               






Page:  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