Julian O. Von Kalinowski and Penelope J. Von Kalinowski - Page 9

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          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.                                                           

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