Ella Freidus - Page 3

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          liable for the additions to tax under sections 6651(f) and                   
          6653(b), the parties have stipulated that petitioner would then              
          be liable for the accuracy-related penalty attributable to                   
          negligence or disregard of rules or regulations under section                
          6662(a) for the 1987, 1988, 1989, and 1990 taxable years.                    
                                   FINDINGS OF FACT                                    
               Petitioner resided in Cold Spring Harbor, New York, when the            
          petition was filed.  Petitioner is married to Jacob Freidus.                 
          Petitioner maintained separate finances from Mr. Freidus during              
          the years in issue.                                                          
               Prior to her marriage to Mr. Freidus in 1967, petitioner was            
          an art dealer who collected art for an art gallery she owned on              
          Long Island, New York.  She was also an agent for a well-known               
          Russian artist.  During the operation of her art gallery,                    
          petitioner maintained books and records and filed tax returns.               
               Petitioner was a successful real estate investor and fine               
          art collector.  Petitioner engaged in several profitable real                
          estate transactions prior to her marriage to Mr. Freidus.  Upon              
          petitioner's marriage to Mr. Freidus, petitioner received 7                  
          properties from him.                                                         
               Petitioner collected jewelry, antique rugs, and Picasso                 
          ceramics during the years in issue.  Items in petitioner's art               
          collection have often been displayed in museums throughout the               

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