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for the transaction wherein Kirk Kerkorian sold the MGM library
(for the first time) to Ted Turner.
In 1990, Mr. Ackerman was invited to become a visiting
scholar at the International Institute for Strategic Studies in
London. He stayed there until 1994 while he wrote and published
a 400-page book called “Strategic Nonviolent Conflict.” During
this period, Mr. Ackerman met Mr. Lerner. Mr. Lerner represented
Mr. Ackerman in certain legal matters, including issues stemming
from Drexel Burnham’s bankruptcy and issues relating to Mr.
Ackerman’s estate planning.
C. Somerville S Trust
During the taxable years at issue and at all relevant times,
Mr. Ackerman was the beneficiary of the Somerville S Trust, which
was treated as a grantor trust for Federal income tax purposes.
All items of income, expense, or loss from Somerville S Trust
were reported on Mr. Ackerman and his wife’s joint Federal income
tax returns.
Somerville S Trust was the capital source for many of Mr.
Ackerman’s investments, including the transaction involving the
Credit Lyonnais group. Mr. Lerner was the trustee of the
Somerville S Trust, and he was fully empowered to transfer or
invest its assets.
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