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returns at issue without reviewing their contents. At no point
did petitioner request an explanation of the returns prior to
signing them.
Each of the returns at issue was signed by Mr. Breitbard on
behalf of Price Waterhouse as the paid preparer. Mr. Breitbard
did not highlight for Mr. Von Kalinowski any potential problems
with respect to the tax benefits claimed from the tax shelter
investments, and Mr. Von Kalinowski believed the returns to be
correctly prepared when he signed them.
Contents of Tax Returns
Mr. Von Kalinowski’s distributive share of income from his
law firm for the 1981 and 1982 taxable years was $391,474 and
$291,348, respectively. In addition, the legal treatises which
Mr. Von Kalinowski authored generated gross income of $65,171 and
$78,915 for the 1981 and 1982 tax years, respectively.
The tax shelter investments generated combined losses of
$368,675 for the 1981 tax year. For the 1982 tax year, the
combined partnership losses were $228,133. Furthermore, in 1982
the tax shelter investments generated an investment income tax
credit of $13,616 with respect to which petitioners filed the
Forms 1045.
Petitioners’ Current Financial Status
Throughout the term of their marriage, petitioners have
utilized income received by Mr. Von Kalinowski for their joint
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