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petitioner all of the liabilities he had assumed in connection
with the dissolution of the partnership, and, before 1995,
petitioner paid the transferred liabilities.
Petitioner’s claims with respect to ownership of intangible
assets are inconsistent and dubious. Petitioner’s conflicting
statements leave unclear which entity owned the client files,
client list, and associated goodwill.
Kaufman, testifying in his capacity as petitioner’s
president, stated:
among the assets received out of the partnership were
client files, a client list, and a going concern value
[goodwill] associated with them, as well as tangible
equipment and other assets that were received out from
that partnership at that time.
Subsequently, I transferred individually the
client files to the * * * law corporation, Jack H.
Kaufman, A Professional Corporation * * *
I also individually kept all other assets
associated with the partnership distribution
individually for about a year, and then I formed JHK
Enterprises * * *
In connection with the formation of that entity, I
transferred all the assets, as well as all the
liabilities, that had been received in connection with
that liquidating distribution to that entity. * * *
between 1987 and ‘95, those assets were leased to the
law corporation pursuant to written leases, which are
part of the stipulated record and exhibits * * *
According to this testimony, Kaufman transferred client files he
acquired in connection with the dissolution of the partnership to
Jack H. Kaufman, APC, not to petitioner. The written leases,
which Kaufman stated are part of the stipulated record and
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