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Jackson. In 1981, they acquired property at 1616 South Carolina
and, in 1982, property at 2501 North 25th Street.
During the years in issue, Tim Radder, a certified public
accountant (C.P.A.), prepared petitioner and her husband's
returns. Petitioner's husband's secretary would compile the
information needed by the C.P.A. to complete the tax returns.
Petitioner would compile the information relating to the expenses
associated with her own real estate activities and any charitable
contributions that she made. Petitioner would sign the return
when her husband's secretary called to tell her the completed
return was available. Petitioner testified that no one ever
explained to her the different deductions or schedules on her tax
return, nor did she ask anyone to explain the return or the
deductions on it. Petitioner further testified, however, that no
one prevented her from examining the returns in issue; instead,
she simply chose not to examine them.
Petitioner testified at trial that she had no knowledge of
her husband's investments in either the Oxnard Properties or
Progressive Properties partnerships. However, Sol Finkelman or a
member of his accounting firm, petitioner, and Robert Somervill
met for lunch or dinner, during which there was some discussion
of the Oxnard Properties and Progressive Properties. Petitioner
testified that she did not understand what was being discussed as
to Oxnard Properties and Progressive Properties. Nonetheless,
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