Estate of Mark R. Woodward, Deceased, Lillian H. Woodward, Executrix, and Lillian H. Woodward - Page 4

               Mr. Woodward attended the University of Illinois for 3                 
          years, but did not obtain a college degree.  During the taxable             
          years at issue, Mr. Woodward worked as a district sales manager             
          for the Master Builders division of the Martin-Marietta Corp.               
          Mr. Woodward retired in 1982.                                               
               Petitioner and Mr. Woodward maintained a joint checking                
          account for the taxable years 1980 through 1983.  Prior to Mr.              
          Woodward's retirement, petitioner and Mr. Woodward shared the               
          clerical tasks concerning household expenses.  For example, both            
          Mr. Woodward and petitioner paid the mortgage and utility bills.            
          However, Mr. Woodward was responsible for the family's financial            
          planning, including tax preparation.  After his retirement, Mr.             
          Woodward managed the family's financial affairs, including paying           
          household expenses, without the help of petitioner.  Mr. Woodward           
          recorded family financial matters on his computer.  Petitioner              
          did not know how to operate the computer.                                   
               On December 8, 1983, Mr. Woodward invested in a tax shelter            
          promoted by Saxon Energy Corp. (Saxon).3  Thomas Graham of Graham           
          & Associates introduced Mr. Woodward to the Saxon Energy                    
          investment.  Petitioner knew Mr. Woodward was considering making            
          an investment with Graham & Associates, but did not know anything           
          specifically about the Saxon tax shelter.  When petitioner's                
          signature was needed on the investment documents, Mr. Woodward              



          3 See Schillinger v. Commissioner, T.C. Memo. 1990-640,                     
          affd. per order 1 F.3d 954 (9th Cir. 1993) (discussing the Saxon            
          Energy program in some detail).                                             



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