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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