Wendlyn H. Albin - Page 3

                                        - 3 -                                         
          petitioner for her signature, and she signed all of the returns             
          without reading or examining any part of them.  She also did not            
          ask Albin, or receive from him, any question as to any item or              
          amount that appeared on the returns.                                        
               In or about December 1982, Albin invested in a tax shelter             
          (shelter) that was in the form of a limited partnership named               
          York Leasing Associates.  The understatements in issue stem from            
          tax deficiencies resulting from that shelter and, more                      
          specifically, the Albins’ reporting of losses for the subject               
          years of $340,244, $249,398, $129,232, and $58,995, respectively,           
          that the shelter passed through to Albin in his capacity as one             
          of its partners.  Exclusive of these losses, the Albins reported            
          on their 1983 through 1986 tax returns total income (primarily              
          from the salary Albin received from a company he owned) of                  
          $322,727, $225,496, $282,557, and $338,243, respectively.  With             
          those losses, the Albins reported that they had relatively little           
          or no Federal income tax liability and that they were entitled to           
          refunds of almost all of the Federal income taxes withheld from             
          Albin’s salary.3  Albin spent the taxes that the Albins would               

               3 The Albins reported on their 1984 return that they had no            
          tax liability and $17,062 of tax withheld from Albin’s salary.              
          The Albins reported on their 1985 return that they had a $12,656            
          tax liability and $25,425 of tax withheld from Albin’s salary.              
          The Albins reported on their 1986 return that they had an $891              
          tax liability and $14,716 of tax withheld from Albin’s salary.              
          The stipulated copy of the Albins’ 1983 return does not contain             
          the page on which they reported their tax liability and withheld            
                                                             (continued...)           





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