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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
filed.
Background
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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