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costs of her art purchases were as follows: $89,094, $14,850, and
$199,030 in the taxable years 1987, 1988, and 1990, respectively.
In 1988 and 1989, petitioner borrowed a total of $635,069 from
Sotheby's. Petitioner partially repaid these loans with the
following amounts disbursed from the Ivory Land account: $48,953,
$83,561, $25,843, and $73,074 in 1987, 1988, 1989, and 1990,
respectively. Petitioner also used funds from the Ivory Land
account to buy various art works from Christie's as follows:
$16,535, $9,906, and $143,610 in 1987, 1988, and 1990,
respectively.
Petitioner retained Eisner & Lubin on June 5, 1989, to
prepare her and her corporate nominees' 1987 and 1988 tax
returns. Eisner & Lubin made repeated requests for records and
information to complete petitioner's individual and corporate tax
returns. Petitioner failed to provide Eisner & Lubin with
adequate records and documentation to prepare the returns for
petitioner and her nominee corporations for the years in issue.
Petitioner did not timely pay Eisner & Lubin for services
rendered in their attempt to prepare petitioner's income tax
returns for the taxable years 1987 and 1988. Petitioner's
delinquency in paying Eisner & Lubin for their services for the
1986 and prior taxable years had also been an ongoing problem.
Petitioner received a letter from Eisner & Lubin dated October
21, 1987, stating that Eisner & Lubin had discontinued
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