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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011