Julian O. Von Kalinowski and Penelope J. Von Kalinowski - Page 7

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          and she was responsible for handling Mr. Von Kalinowski’s                   
          everyday financial affairs.  For instance, Ms. Hester received              
          and deposited Mr. Von Kalinowski’s paychecks, she paid all                  
          routine expenses such as insurance payments, mortgage payments,             
          and she made the payments due on Mr. Von Kalinowski’s outstanding           
               Given the responsibilities undertaken by Ms. Hester,                   
          petitioner’s knowledge of the particulars of her husband’s                  
          finances was limited.  Petitioner, however, was aware that Mr.              
          Von Kalinowski made investment decisions on their joint behalf,             
          and she allowed him to do so without seeking her approval.                  
          Husband’s Tax Shelter Investments                                           
               Respondent determined the deficiencies for the years at                
          issue based on the distributive shares of the following                     
          partnerships:  Diversified Investments Group (Diversified),                 
          Capricorn Company (Capricorn), and Pisces Company (Pisces)                  
          (collectively, the tax shelter investments).  Mr. Von Kalinowski            
          invested approximately $10,000 in Diversified upon the suggestion           
          of a law partner and following a meeting with Diversified’s                 
          promoter.  Mr. Von Kalinowski did not consult petitioner with               
          respect to this investment.                                                 
               Mr. Von Kalinowski became interested in Capricorn and Pisces           
          (the partnerships) when another law partner introduced him to an            
          individual named Togo Tanaka.  In addition to being a member of             

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