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a return is an exceedingly laborious one. In 1986 the
corporation was terminating its involvement in
approximately 400 leasing transactions which must be
properly analyzed.
Petitioner was aware that Trupin had cashflow problems in 1987.
Petitioner was also aware that 1986 tax law changes had adversely
affected the viability of Trupin’s tax shelter businesses. She
signed a letter dated October 31, 1984, resigning as an officer
of The Rothschild Collection, Ltd.; yet, on August 6, 1987,
petitioner executed, as president, a Certificate of Amendment of
the Certificate of Incorporation of The Rothschild Collection,
Ltd.
Notwithstanding financial difficulties resulting from the
decline of Trupin’s tax shelter businesses, petitioner continued
much of the lifestyle that she had previously enjoyed, driving
one or more Rolls Royce automobiles; acquiring residential
properties and a boat; and dealing in antiques, art, and jewelry
as set forth below. Beginning in 1986, petitioner and Trupin
maintained separate residences. They continued to cooperate,
however, with respect to the disposition of assets and,
ultimately, in transferring assets outside of the United States,
as set forth below. Petitioner did not file a Federal income tax
return for any year from 1987 through 2001.
In 1986, Trupin purchased a home in Tortola, British Virgin
Islands (Tortola), for petitioner for $150,000. In 1988, Trupin
and petitioner began incorporating companies outside the United
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