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During the years at issue, petitioner did not buy any
jewelry or expensive clothes. She drove a 1980 station wagon.
During this period, the Audes took one vacation to Hawaii in
December of 1982. Until their divorce, petitioner and Mr. Aude
lived in the same house, which they purchased in 1976. They had
built an addition to that house in 1978-79.
Throughout their marriage, petitioner and Mr. Aude
maintained a joint bank account. Initially, Mr. Aude handled all
the finances. In 1978, Mr. Aude gave petitioner a monthly
allowance of $3,000 to pay the household bills. This monthly
allowance was used to pay Mr. Aude's alimony and child support to
his ex-wife, household bills, food, and medical expenditures.
While the allowances at times decreased during the years at
issue, they never increased. Using her monthly allowance,
petitioner wrote checks out of the joint bank account, and
recorded the checks in her register; however, the Audes
maintained separate check registers. Petitioner never saw the
checks Mr. Aude wrote or his check register. Petitioner never
examined the bank statements because it was Mr. Aude's job to
review the bank statements.
Petitioner was uninvolved in the business affairs of Mr.
Aude. Occasionally, petitioner would accompany Mr. Aude to
business meetings, but after introductions she would stay in the
lobby or in the car during the actual meeting. She was unaware
of Mr. Aude's salary and his investment income. If petitioner
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