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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...)
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