Ralph Tashjian - Page 3

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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in San Francisco, California, at the time that           
          he filed his petition.                                                      
          The Synergistics, Lumenetics, and Data Flex Partnerships                    
               Beginning in 1980 to the present, petitioner has been in the           
          record promotion business working for various record companies.             
          During the 1980s, he was employed by Joseph Isgro (Isgro).                  
               While working for Isgro, petitioner was introduced to                  
          Isgro’s tax attorney, DiRicco.  Through DiRicco, petitioner                 
          became involved in a number of partnerships.                                
               In 1982 petitioner was a limited partner in Synergistics.              
          Synergistics recorded its Certificate of Limited Partnership on             
          October 13, 1983, in San Mateo County, California.  An amendment            
          to the Certificate of Limited Partnership was recorded on                   
          November 10, 1983.  Petitioner and his wife at the time, Valerie            
          A. Tashjian (Mrs. Tashjian), made a $60,000 capital contribution            
          to Synergistics at the time that it was formed.  The Certificate            
          of Limited Partnership lists petitioner as a limited partner and            

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Last modified: May 25, 2011