- 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