Mr. Alioto is not a tax expert, nor has he any background in tax law.
Neither does respondent dispute that Mr. Alioto was involved in a complicated business transaction.
Alioto contends that he believed he would be reimbursed by Ratzenberger for all of the BRT-related expenses.
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Mr. Alioto testified that a business plan named Big Rent Tent (BRT) was developed, which included multiple celebrities.
The plaintiffs are represented by the Alioto Law Firm, Gray Plant Mooty and Messina Law Firm PC.
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Mr. Alioto was reimbursed for some of his expenses but, at least by his reckoning, not all of them.
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Which is probably why former San Francisco Mayor Joe Alioto (1968-1976) once called this Beaux Arts estate his home.
Based on the e-mail, Mr. Alioto claimed a theft loss deduction for 2005, which carried over to 2006 and 2007.
Mr. Alioto had not saved the 2005 email from Mr. Ratzenberger that convinced him that there would be no further reimbursements.
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If Mr. Alioto had kept a Big Red Tent folder with copies of correspondence and emails, he might have done a lot better.
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We believe that Mr. Alioto did in fact make a good faith effort on the basis of his knowledge of the facts and understanding of the law.
Most are women under financial pressure, and some come from privileged backgrounds: Past relief recipients include wives of former San Francisco Mayor Joseph Alioto and Levittown developer William Levitt.
At trial Mr. Alioto claimed that a formal agreement did exist between himself and Mr. Ratzenberger but that he had left it at home and did not want to share it with anyone.
Mr. Alioto did not present any evidence demonstrating that Mr. Ratzenberger or his agents did anything illegal and failed to show any specific promises or agreements made by Mr. Ratzenberger and his agents.
Mr. Alioto never contacted the police, the Securities and Exchange Commission, or any State licensing division, never filed suit against Mr. Ratzenberger, and never had any written contract between himself and Mr. Ratzenberger.
Alioto testified that he agreed to join the venture as a CEO and agreed to provide services including setting up the office operations and meeting with investment and venture firms to raise capital for the business.
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