- 7 - 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 loans. 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011