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Petitioner did not know that Gerald had invested in the tax
shelters, and she had no ownership interest in them. She also
did not know that Ajac had invested in the tax shelters.
Petitioner was not present when the tax shelters were
discussed, and she never saw the tax shelter documents. Gerald
never discussed the tax shelter investments with her. When
petitioner noticed the amount of mail they received from the
Internal Revenue Service for prior tax years, she asked Gerald
what was going on. Gerald told her that Gelda was the
accountant, everything was under control, and she should not
worry about it.
Gerald invested in the following tax shelters: Hawk Mining,
Masada Press, Ltd., Mason Coal, Power Control Sales Corp. (Power
Control), and T.A.B. Production.
For the taxable year 1978, Gerald claimed deductions of
$3,956, $49,472, $5,203, and $24,144 attributable to the
investments in Hawk Mining, Masada Press, Ltd., Mason Coal, and
T.A.B. Production, respectively. Gerald claimed an investment
tax credit of $42,800 attributable to the investment in Masada
Press, Ltd., for the taxable year 1978.
For the taxable year 1979, Gerald claimed deductions of
$3,853, $60,000, and $32,396 attributable to the investments in
Hawk Mining, Masada Press, Ltd., and Power Control, respectively.
Gerald claimed an investment tax credit of $28,600 for the
taxable year 1979, but the record does not make clear to which
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