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manufacturing laboratory, and a storage warehouse. Five
buildings are located on the west side and consist of both office
and warehouse or industrial space, some of which is leased to
third-party tenants.
In operating their businesses, petitioners employed the
services of several professional advisers. Robert J. Hartmann,
an attorney, certified in Arizona as a tax law specialist in past
years and also holding a degree in accounting, met Mr. Deihl in
1983 and became involved in legal work for Mr. Deihl and his
companies. Mr. Hartmann initially assisted with contract
disputes and organizational issues, and by 1998 approximately 70
percent of his practice was devoted to providing services for
petitioners and their entities. At that time and at Mr. Deihl’s
request, Mr. Hartmann relocated to an office on 24th Street to be
closer to the corporate headquarters.
With respect to the accounting function, prior to about the
1991 to 1992 period, petitioners had employed the services of an
outside accounting firm, referred to as “Duskin & Duskin”,
apparently working principally with Bernie Duskin, alleged to be
a certified public accountant (C.P.A.). Mr. Duskin introduced
Mr. Deihl to Martin D. Goltz, recently arrived in Arizona from
Illinois. Mr. Goltz had received from DePaul University in
Chicago, Illinois, a degree in accounting in 1964 and then a
juris doctorate in 1967. Mr. Goltz was licensed by the State of
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