- 9 - investments in the tax shelter investments. Not only did Mr. Von Kalinowski not consult petitioner prior to investing, he did not discuss the investments with her during the tax years at issue. The Schedules K-1, Partner’s Share of Income, Credits, Deduction, etc., issued by the partnerships to Mr. Von Kalinowski were sent to his home address. It was petitioner’s general practice, however, not to open mail addressed to her husband. Upon receipt, Mr. Von Kalinowski would forward the Schedules K-1 to his accountant. Preparation of Income Tax Returns The tax returns for the years at issue were prepared by Stanley Breitbard, a certified public accountant with the firm of Price Waterhouse. As a means of compiling the information necessary to prepare the couple’s return, Price Waterhouse sent various informational schedules to Mr. Von Kalinowski for completion. These schedules were completed by Ms. Hester on Mr. Von Kalinowski’s behalf.8 Petitioner compiled the tax information relating to her sole proprietorship and forwarded such information to the accountant. After the return was completed, either Mr. Breitbard or someone from his office would review it with Mr. Von Kalinowski. Mr. Von Kalinowski would then take the return home for petitioner’s signature. Petitioner consistently executed the 8 Mr. Von Kalinowski’s business address was used for each of the returns at issue because the couple’s tax records were maintained there.Page: 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