Julian O. Von Kalinowski and Penelope J. Von Kalinowski - Page 10

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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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