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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
world.
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