Malcolm I. Lewin and Trina Lewin - Page 14

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          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 petitioner or the memorandum.                
          Dooskin made no separate charge to petitioner 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             
          Co., submitted a protest letter (protest letter) to respondent on           
          behalf of SAB Management.  The protest letter included the                  
          following statement:                                                        
               We hereby agree to follow the Tax Court’s decision in                  
               the lead cases selected in accordance with the Order of                
               June 12, 1987, such cases being:                                       
                    1. Elliot I. Miller, Petitioner                                   
                    v. Commissioner of Internal Revenue, Respondent,                  
                    Docket No. 10382-86                                               

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