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Petitioner and Mr. Von Kalinowski borrowed the funds for
petitioner’s share of the startup costs. In 1985, petitioner and
Mr. Von Kalinowski bought out petitioner’s co-owner in the travel
agency for approximately $25,000.
Windsor Travel was operational from 1984 to 1999. Over this
time period, Mr. Von Kalinowski invested over $500,000 in the
business on behalf of petitioner, and such amounts were used to
fund the operations of the agency. In 1999, petitioner sold the
assets of Windsor Travel for approximately $25,000 plus a sliding
percentage of revenue generated from the transferred accounts.
Financial Matters
Petitioner and her husband maintained two bank accounts.
While each of these accounts was titled in the couple’s joint
names, the couple regarded one as petitioner’s checking account
and the other as Mr. Von Kalinowski’s checking account.
Petitioner used the funds in her checking account to pay the
couple’s grocery bills and other personal expenses, and Mr. Von
Kalinowski made periodic deposits into this account for such
purposes. The bank statements on petitioner’s checking account
were sent to the couple’s residence and received by petitioner.
The bank statements on Mr. Von Kalinowski’s checking account
were sent to his office and received by his secretary, Gina
Hester. Ms. Hester served as Mr. Von Kalinowski’s personal
secretary from 1952 until just prior to his retirement in 1985,
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Last modified: May 25, 2011