- 11 - investment in that company. It was only after Riverside filed for bankruptcy in 1989 that petitioner became aware that Mr. Korchak had invested approximately $700,000 in that company. As was true of petitioner’s reliance on Mr. Korchak with respect to their family’s finances, petitioner also relied upon Mr. Korchak to retain a professional to prepare joint tax returns for them. Petitioner’s role in the preparation of such returns was limited to providing Mr. Korchak with any Forms W-2, Wage and Tax Statement (Form W-2), and Internal Revenue Service (IRS) information returns that she received as well as any other tax- related information that she had. Since around the mid-1970s until the time of the trial, the professional that Mr. Korchak retained to prepare Form 1040, U.S. Individual Income Tax Return, for petitioner and himself (joint tax return) was Hilton Sokol (Mr. Sokol), a certified public accountant. Mr. Sokol was an employee of Miller, Ellin and Company (Miller Ellin) in New York, which provided accounting services for, inter alia, Halcon. Many of Halcon’s executives retained certified public accountants employed by Miller Ellin to prepare their respective tax returns. Both petitioner and Mr. Korchak trusted and relied on Mr. Sokol’s professional judgment to prepare accurately their joint tax returns. Since around the mid-1970s, the following general practice remained the same with respect to (1) the preparation of jointPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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