Julian O. Von Kalinowski and Penelope J. Von Kalinowski - Page 3

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          return.  On their 1982 return, petitioners claimed an investment            
          tax credit in excess of their income tax liability.  Petitioners            
          accordingly filed joint and separate Forms 1045, Application for            
          Tentative Refund, in order to apply the excess credit against               
          their tax liabilities from prior years.3                                    
               Petitioner was born and educated in the United Kingdom.  She           
          graduated from the London College of Secretaries in 1967, and she           
          attended Saint Thomas College from 1975 to 1976.  During her                
          studies at Saint Thomas College, petitioner completed a one                 
          semester course in financial accounting.                                    
               From 1972 until 1978, petitioner was employed by Pfizer                
          Corp. (Pfizer) to coordinate the provision of secretarial and               
          administrative services to a team of lawyers that represented the           
          company in ongoing antitrust litigation.4  While working at                 
          Pfizer, petitioner met her future husband, Julian O. Von                    
          Kalinowski.  An experienced attorney with the firm of Gibson,               
          Dunn and Crutcher, L.L.P., Mr. Von Kalinowski led the team of               
          attorneys for whom petitioner provided administrative support.              

               3  In addition to jointly filing Form 1045 seeking a                   
          carryback of the excess investment credit to 1980, petitioners              
          separately filed Forms 1045 seeking a carryback of the excess               
          investment credit to 1979 (a tax year which preceded petitioners’           
               4  Petitioner’s accounting responsibilities at Pfizer                  
          consisted of limited bookkeeping, which was mostly handled by a             
          secretary on her behalf.                                                    

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