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as Grant Thornton. He became a partner in 1970, and when he left
the firm in 1986 for employment by a client, Dooskin was the
managing partner of the New York office and chairman of the
firm’s executive committee. Dooskin was primarily an auditor and
was not a tax accountant. Dooskin had met Lewin when they were
in college, and they served together in the Army. In 1982, Lewin
brought the SAB Foam memorandum to Dooskin for review. Dooskin
passed the memorandum on to Ronald Sacco (Sacco), a tax
professional at Alexander Grant, for review. According to
Dooskin, Sacco’s view was that the investment and the economics
of the deal were “dependent upon the valuation of the equipment”.
After Dooskin and Sacco each spent about 3 hours reviewing the
matter, Dooskin concluded that the proposal “looked like a
legitimate business, * * * compressing plastic, and that it was
better than most”. Neither Dooskin nor Sacco performed an
independent analysis of the valuation of the recyclers. All of
Dooskin’s and Sacco’s information relating to the valuation of
the recyclers came from either Lewin or the memorandum. Dooskin
made no separate charge to Lewin for the few hours he and his
associate spent examining the memorandum.
D. Partnership-Level Litigation
On August 15, 1988, respondent issued a notice of proposed
adjustments to tax return to SAB Foam for 1982 and 1983. On
September 28, 1988, Robert L. Steele, a tax partner with Becker
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