H. Robert Feinberg - Page 14

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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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