District Court, S.D. New York March 22, 2001, 00 Civ. 0771(SAS), 00 Civ. 6484(SAS) (Diversified Group, Inc. v. Daugerdas)

OPINION AND ORDER

SCHEINDLIN, District Judge.

These actions, which have been consolidated for all purposes, arise from a dispute between The Diversified Group, Inc. (“DGI”) and Paul Daugerdas, in connection with the Optional Partnership Strategy (“OPS”), a tax strategy designed to enable individuals or corporations to achieve tax savings through the use of European-style digital options.