- 19 - an economic investment. Petitioner never saw the subscription agreement or either of the assumption agreements or any other documents, including the Memorandum, relating to the Stonehurst investment, either prior to Mr. Heitzman’s purchasing the interest or at any time thereafter. Mr. Heitzman kept the Stonehurst documents at his office and signed the subscription and assumption agreements there without ever bringing them home. 4. The 1979 Joint Income Tax Return In each of the taxable years from 1973 to 1981, including 1979, petitioner and Mr. Heitzman filed joint Federal income tax returns that were prepared by a prominent accounting firm, Alexander Grant, Inc. (Alexander Grant). Each year, when Mr. Heitzman asked, petitioner would give him her Forms W-2, receipts, and other information pertaining to her employment. He would then pass that information to their accountant at Alexander Grant, along with the other information required to complete the return. For taxable year 1979, Mr. Heitzman helped petitioner determine the expenses for her modeling activities by going through the checkbook and other receipts. Petitioner’s 1979 gross income amounted to $3,700, derived entirely from residuals from a television commercial. Petitioner had $3,058 in total deductions, including agency fees and modeling expenses, that were attributable directly to her business activities that year. Her net contribution to taxable income shown on the return was $642.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011