Jacob and Chana Pinson, et al. - Page 17




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          carried on real estate rental activities through a variety of               
          passthrough entities.  The Federal income tax returns of                    
          individuals involved in these ventures reported the income or               
          loss therefrom on Schedules E.  Dividends from these entities, as           
          well as from Deitsch Sales, were reflected as “Dividend income”             
          on their Forms 1040 and the accompanying Schedules B.                       
          The Preparation and Examination of the Deitsch Returns                      
               The combined financial statements and the tax returns for              
          DPC, DPP, Deitsch Sales, and various real estate entities were              
          prepared by the accounting firm of Weinstein & Anastasio, P.C.              
          The tax returns here at issue of individual members of the                  
          Deitsch family were also prepared by the firm.  Anthony                     
          Valentino, a certified public accountant, has been petitioners’             
          primary accountant at the firm since the mid-1980’s.  The                   
          financial statements and tax returns for FIL were prepared by               
          petitioners’ accountant in Israel, Itzhak Timor.                            
               For purposes of preparing these documents, Mr. Valentino was           
          given access to the records for the Deitsch entities kept at the            
          corporate facility in West Haven.  The individual family members,           
          although they did not typically fill out the annual questionnaire           
          sent by the accounting firm, would provide original data such as            
          Forms W-2 and Forms 1099.  Information regarding the payments               
          from FIL was obtained from the FIL financial statements sent to             








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