- 39 - however, was sophisticated in real estate and business matters and was aware that Albrecht was interpreting the partnership agreement in a way that was incorrect. During trial, Hillgren admitted that he knew better and that he had negotiated better, yet he was willing to take the inconsistent positions on the returns knowing that it would benefit his children and, implicitly, that he would avoid or reduce tax on the distributions. Respondent also questioned why Albrecht instructed M. Higgins to appraise the limited partnership interest as though Hillgren had a 25-percent profit interest, although the partnership tax returns were filed with a .05-percent interest. Respondent’s questions related to a letter written by Albrecht to Higgins, Marcus & Lovett, Inc., regarding how to appraise Hillgren’s interest. Albrecht testified as follows: Q You advised Mark Higgins to appraise the partnership interest as though Mark Hillgren had a 25 percent profits interest in the partnership, correct? A Well, I don’t know if I did or not, or whether I’m-- Q You can take a minute and look at the letter if you need to. A Well, I don’t know--I just don’t recall, I--this letter is obviously written as a response to the report that they had written and I would have to compare it to the report to see what I actually recommended by this. I--it’s obviously something that I had my office type up, and I signed the letter, but I would have toPage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
Last modified: May 25, 2011