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Magnum, but Mr. Aude did not disclose the tax shelter nature of
the investment to petitioner. She never saw the investment
papers concerning Magnum, and she was unaware of Mr. Aude's
capital contribution in Magnum.
1980, 1981, 1982 Joint Income Tax Returns
For the years at issue, Mr. Gruys prepared the Audes'
Federal income tax returns. He only occasionally talked with
petitioner, generally around the tax preparation time. Instead,
he generally saw Mr. Aude. Petitioner's main involvement in
completing the returns was to compile a list of household
expenditures for Mr. Gruys. She would accompany her husband to
deliver the list to Mr. Gruys. After preparation, Mr. Aude would
present the returns, folded to the signature page, for
petitioner's signature. At these times, both Mr. Aude and Mr.
Gruys had already signed the return. Prior to signing the
returns, petitioner did not review them.
In regard to the Magnum investment, Mr. Gruys never reviewed
any papers regarding the investment. In preparation of the tax
returns for the years at issue, Mr. Gruys relied on the Schedules
K-1 prepared by Magnum. In advising the Audes, Mr. Gruys did
speak with Mr. Aude in passing regarding the validity of the
deductions for the investment, but he did not talk with
petitioner about the deduction.
The joint returns for 1980, 1981, and 1982, as originally
filed, reflect income, Magnum deductions, adjusted gross income,
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