- 3 -
FINDINGS OF FACT
Petitioners were married in 1959 and were still married at
the time of trial. Throughout the relevant years, they resided
in a house they bought in 1972 or 1973 for approximately $118,000
located at 109 Piermont Avenue, Hewlett Bay Park, New York.
Petitioner Harvey I. Epstein (Harvey) is a graduate of
Dartmouth College. After graduation, he held several jobs, and
was President of Dreyfus Sales Corporation for a period of time
until 1970 or 1971, when he left Dreyfus and became a consultant.
During the relevant years, Harvey was a general partner and
investor in certain limited partnerships which generated
substantial putative losses, which petitioners claimed as
deductions on their return for the relevant years.
Harvey earned a salary from Harvey I. Epstein, Ltd., which
was reflected on W-2 forms and reported on petitioners' tax
returns for the relevant years. In 1978 Harvey also received a
$21,867 salary from Pace Funding Corp., also reflected on a Form
W-2, and duly reported on petitioners' 1978 return.
Arlene is a graduate of Barnard College. She also received
a Master's degree in Education from Columbia, and a Master's
degree in Humanities from Hofstra University. Arlene was
employed as a teacher for 5 or 6 months shortly after her
marriage, but stopped teaching when she became pregnant, and
never returned to teaching. When her daughter attained age 10,
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011