- 3 - interest in General Investment Group (GIG) partnership. GIG was a partner in Salmon Realty partnership. Salmon Realty was one of many partnerships which made up the Kilpatrick shelter. Petitioner and Vida Lee (his former spouse)2 filed a joint Federal income tax return for 1980 (1980 return) claiming partnership losses from GIG totaling $20,705. On April 12, 1984, respondent issued a notice of deficiency to petitioner and Vida Lee disallowing the partnership losses of GIG. Respondent issued similar notices of deficiency to other investors in GIG. On July 2, 1984, with petitioner's knowledge and on behalf of petitioner and other investors in GIG, Declan O'Donnell (Mr. O'Donnell), an attorney, filed a petition in this Court contesting respondent's disallowance of GIG's losses (the GIG case). Mr. O'Donnell filed numerous other petitions on behalf of investors in other Kilpatrick shelter partnerships contesting respondent's disallowance of similar losses (collectively, the civil cases). In 1979, the Securities and Exchange Commission (SEC) began investigating Mr. Kilpatrick and Mr. O'Donnell regarding their promotion of interests in the Kilpatrick shelter. In 1982, in a 27-count indictment, Mr. Kilpatrick and Mr. O'Donnell were charged with conspiracy to defraud the Internal Revenue Service (IRS) by claiming false partnership deductions in violation of 18 2 In 1989, petitioner and Vida Lee divorced.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011