Debra L. Streck and Donald W. Streck - Page 16

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          forthright concerning the couple's income, Adams v. Commissioner,           
          60 T.C. 300, 303 (1973), and (3) the presence of unusual or                 
          lavish expenditures, Mysse v. Commissioner, 57 T.C. 680, 699                
          (1972).  Another factor the courts have focused on is whether the           
          couple's standard of living improved significantly during the               
          years in issue.  Id. at 698-699.                                            
               Mrs. Streck participated in the business affairs and                   
          bookkeeping of petitioners' businesses.  During the years in                
          issue, Mrs. Streck was the sole shareholder of ACI.  Mrs. Streck            
          was a signatory on ACI's bank account, and she signed checks as             
          an officer on behalf of ACI.  She also participated in voting on            
          resolutions adopted by the board of directors of ACI.  Mrs.                 
          Streck was an officer of P.G.D., a corporation wholly owned by              
          Mr. Streck.  Mrs. Streck testified that she wrote and signed                
          checks for all of petitioners' businesses including ACI.  She               
          also testified she made deposits to corporate bank accounts and             
          paid invoices from corporate accounts.  We find that Mrs. Streck            
          substantially participated in petitioners' combined business                
          affairs.                                                                    
               Mrs. Streck provided absolutely no evidence or argument that           
          Mr. Streck refused to disclose information or was not forthright            
          with her regarding their financial affairs.                                 
               Family expenditures during the years in issue appear to be             
          lavish within the meaning of Mysse v. Commissioner, supra at 699.           
          During 1984, through Double D Ranch, Inc., petitioners                      




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