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the local Rotary club, Mr. Tanaka was represented to be a member
of the board of governors of the Federal Reserve Bank of San
Francisco. Mr. Tanaka in turn introduced Mr. Von Kalinowski to
Philip Siriani, a businessman who had contacts with a local bank
willing to finance the investment in the partnerships. Mr.
Tanaka’s position in the community and Mr. Siriani’s apparent
business and political contacts supplied a measure of credence to
the financial benefits and tax advantages purportedly offered by
the partnerships. Mr. Von Kalinowski was further assured of the
partnerships’ legitimacy when informed that a former U.S. senator
was also investing.6
Near the end of 1981, Mr. Von Kalinowski purchased limited
partnership interests in the partnerships. He financed the
investment through a $140,000 bank loan secured by the couple’s
residence. Although the residence was titled in Mr. Von
Kalinowski’s individual name and constituted his separate
property, both Mr. Von Kalinowski and petitioner executed the
deed of trust in favor of the bank.7
Petitioner had limited, if any, knowledge of her husband’s
6 Former U.S. Senator S.I. Hayakawa is listed as a limited
partner on Capricorn’s certificate of limited partnership.
7 Presumably, the bank required petitioner’s signature on
the deed of trust to protect its security interest from any
spousal claims which petitioner may have had against the property
under California property law.
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Last modified: May 25, 2011