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and * * * were constantly working on deals”. In 1978, he formed
a new firm with an attorney who specialized in real estate
transactions, and later that firm merged with LFC.
Feinberg met Becker through Cohen and developed a
professional relationship with him. This relationship included
referrals between LFC and Becker Co., as well as personal
matters. Feinberg considered Becker a very bright and
sophisticated accountant. Becker retained Feinberg to protect
his interests as a promoter of SAB Foam. Becker did not employ
Feinberg to represent the partnership but to advise him for his
own protection. Petitioner did not know Becker personally but
rather knew of him from his relationship with both Cohen and
Feinberg.
Herbert Dooskin (Dooskin) received a B.A. in economics from
City College of New York and an M.B.A. from Baruch College. He
began his career as a financial accountant in 1962 with Alexander
Grant & Co. (Alexander Grant), an accounting firm currently known
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 petitioner when they
were in college, and they served together in the Army. In 1982,
petitioner brought the memorandum to Dooskin for review. Dooskin
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