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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
Background
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’
marriage).
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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