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of land Mr. Jones purchased in 1970 for cash. She knew that Mr.
Jones purchased U.S. savings bonds through his paycheck during
the period 1972 to 1982. She knew about a 5-acre tract of land
near Sealy that Mr. Jones sold in 1982, and how the buyer paid
for it. She knew that Mr. Jones consulted with David Lye about
the purchase of a lumber yard in 1980 or 1981. She knew that Mr.
Jones wanted to build a Holiday Inn in Sealy.
After petitioner found and recommended Mr. Singleton to Mr.
Jones (during 1979 or 1980) and they met with him briefly, Mr.
Jones took responsibility for transmitting all pertinent
information to Mr. Singleton and seeing that their joint income
tax returns were prepared. Mr. Singleton prepared the 1981 joint
income tax return filed by the Joneses. Mr. Singleton found both
petitioners difficult to deal with when he needed information.
The Joneses filed their joint income tax return for the
taxable year 1981 on August 23, 1982. On their 1981 return, the
Joneses claimed deductions with respect to an investment in an
art tax shelter.
In addition to the deductions claimed for the art tax
shelter, the Joneses claimed partnership losses from Auburn
Mining Joint Venture (related to Munro Shuman) (Auburn Mining
partnership) in the amount of $76,674 and Choate Square Joint
Venture (Choate Square partnership) in the amount of $11,798.92.
During 1981, Mr. Jones had invested $10,000 in the Auburn Mining
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