Carla J. Zimmerman - Page 10

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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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