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Petitioner enjoyed a comfortable lifestyle during the years
in issue, but that lifestyle was consistent with that of prior
years. The tax savings from the tax shelter investments were not
used to better petitioner's standard of living; rather, those tax
savings flowed into Gerald's business activities. Gerald
subsequently sold his business activities, and petitioner
received no benefits from those sales.
Gerald generally concealed his business activities and tax
shelter investments from petitioner. Petitioner did not sign the
1978 or the 1980 Form 1040. Petitioner signed the 1979 Form 1040
after being instructed to do so by Gerald. Gerald considered all
matters related to his businesses and the family finances to be
his domain. Gerald did not discuss any investments with
petitioner, including the tax shelter investments, and he had no
interest in discussing those matters with her. Gerald reinvested
the tax savings derived from the tax shelter investments in his
businesses, and he did not discuss this with petitioner.
Petitioner was not present when Gerald met with Gurian or Gelda.
Gelda advised Gerald not to invest in the tax shelters, but
Gerald never shared Gelda's advice with petitioner.
Petitioner satisfied any duty she may have had to inquire as
to the propriety of the tax shelter deductions. Petitioner
reviewed the 1979 Form 1040 as best she could. She saw that
Gelda already had signed the Form 1040, which led her to believe
that the Form 1040 had been prepared properly. Petitioner had
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