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education; the spouse's involvement in the family's business and
financial affairs; the presence of expenditures that appear
lavish or unusual when compared to the family's past levels of
income, standard of living, and spending patterns; and the
culpable spouse's evasiveness and deceit concerning the couple's
finances. Stevens v. Commissioner, 872 F.2d at 1505; Flynn v.
Commissioner, 93 T.C. 355, 365-366 (1989).
Petitioner possessed a high school education and no training
in bookkeeping. She was responsible for running the household,
paying the personal and family expenses, and maintaining the
checkbook for the household account. The money deposited in the
household account, beyond that from petitioner's paycheck while
she was working, came from the business. For a short period
during the years at issue, petitioner assisted her husband in the
business by writing checks. She had access to the checkbook for
the business account at other times. There is no evidence of any
evasiveness or deceit on the part of her husband with respect to
the finances of either the family or the business.
The family's expenses were modest and the amounts deposited
into the household account were in keeping with these expenses.
However, the Zimmermans' tax returns reported extremely small
amounts of business income, much smaller than the amounts
deposited into the household account. In 1988 petitioner wrote
checks on that account of some $16,000 and in 1989 wrote checks
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