Sharon Lee Bartlett, F.K.A. Heitzman - Page 19

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          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.                                        



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