Aleksandrs v. Laurins Cathie Laurins v. Commissioner Internal Revenue Service

Aleksandrs and Cathie Laurins, taxpayers , appeal the decision of the tax court finding a total liability of $866,842.62 for tax years 1973-75. The liability resulted from the Tax Court’s decision that Laurins had received taxable distributions of certain shares during the years in issue, and that he had fraudulently understated his income. On appeal, Laurins contends that:

We reject all of these contentions and affirm the decision of the Tax Court.

BACKGROUND AND PROCEEDINGS BELOW

Aleksandrs V. Laurins is an attorney and a former employee of the Internal Revenue Service. He served as a trial attorney in the National Office Trial Branch of the Tax Court Division for three years. He has held himself out to the public as a tax expert, and has written books and held seminars on tax shelters.

Laurins and the many corporations and partnerships that he set up and controlled were involved in several real estate development projects where apartments were converted and sold individually as co-ops. For example, Laurins formed a non-stock homeowners’ cooperative corporation to acquire the Fairfax West Apartments. The owners’ cooperative assigned its ownership interest to A.V. Laurins &…