Harris Levin and Gayle Levin - Page 2

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          and signed her name to the stipulation for decision without                 
          authority and that his conduct constituted a fraud on the Court.            
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue.                 
          Ms. Levin resided in California at the time the petition was                
               Petitioners were married in 1963, shortly after Ms. Levin              
          graduated from the University of California at Los Angeles with a           
          bachelor of arts in general elementary education.  During the               
          course of their marriage, Mr. Levin was in the construction                 
          business and Ms. Levin was employed as a teacher with the                   
          Los Angeles Unified School District.  They had two children.                
          Petitioners separated during 1975 and reconciled during 1976.               
          Their marriage was ultimately dissolved December 28, 1994.                  
               During the course of their marriage, the parties maintained            
          joint checking accounts.  Ms. Levin wrote checks on joint                   
          accounts to pay the mortgage and other household bills.                     
          Mr. Levin, however, maintained control over the financial affairs           
          of the couple.                                                              
               In 1980, petitioners, along with other members of their                
          tennis club, invested in certain tax shelter partnerships                   
          promoted by Gerald Schulman.  Petitioners' contact with the                 
          Schulman partnerships was through Alan Letterman.  Ms. Levin                

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