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account with Texaco P.A.W. Also, petitioner and Ms. Dawson lent
her sister and her husband $4,400 for the purchase of a truck.
Petitioner also purchased a 28-foot Chris Craft boat for $7,500,
paying for it with withdrawals from the joint checking account
with Texaco P.A.W. Petitioner and Ms. Dawson paid $6,187.85 to
decorate the boat, meeting with the decorator to discuss the
decoration. Petitioner also incurred maintenance expenses of
over $2,825.29 with respect to the boat in 1988. Petitioner paid
yacht club membership and dockage fees of $1,250 with respect to
the boat.
Significant travel financed by petitioner and Ms. Dawson
also occurred during 1988. Petitioner and Ms. Dawson went on a
Caribbean cruise. They gave Ms. Dawson’s parents such a cruise
costing $1,316 as an anniversary present. Petitioner, Ms.
Dawson, and their daughter Audrey went on a vacation costing
$1,190 to Disneyland in California. Petitioner and Ms. Dawson
gave her sister, her husband, their two daughters, and
petitioner’s and Ms. Dawson’s daughter Audrey a vacation costing
$2,656 to Disneyland.
The fourth factor we consider is whether Ms. Dawson was
forthright about the omitted income. Petitioner has not
established that Ms. Dawson was evasive concerning her true level
of income. We have found that Ms. Dawson did not attempt to hide
the income from her embezzlement or her expenditures from
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