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liable for the section 6653(a) additions to tax as determined by
respondent; and (3) whether petitioners Catherine Chimblo and
Estate of Gus Chimblo are liable for the section 6661 additions
to tax for substantial understatements of income tax for 1983 and
1984.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioner Catherine Chimblo resided
in Stamford, Connecticut, and petitioner Josephine Chimblo
resided in Cos Cob, Connecticut, on the dates their respective
petitions were filed in these cases.
Petitioner Catherine Chimblo (Catherine) was married to Gus
Chimblo (Gus) until his death on March 22, 1988. Petitioner
Josephine Chimblo (Josephine) was married to Anthony J. Chimblo
(Anthony) until his death on March 21, 1984.
In December of 1983, Gus and his sister-in-law Josephine
each invested $25,000 in Barrister Equipment Associates Series
151 (the Barrister partnership). Their respective Schedules K-1
from the Barrister partnership show their capital contributed
during 1983 as such amounts. The investments were made on the
advice of the Chimblos' family accountant, John Santella. Mr.
Santella died in 1996, prior to the trial in this case. After
his death, Mr. Santella's son, John Santella Jr., acted as the
Chimblos' accountant.
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