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Mrs. Wilkinson received a bachelor of science degree in
nursing from City College and became a registered nurse in 1986.
Since that time, she has been employed sporadically. In 1987,
she worked for 3 months as a registered nurse. In 1991, she
worked 2 days a week at Dr. Wilkinson's medical practice as a
registered nurse. She knew that Dr. Wilkinson was working and
making money during this time and did not believe that he hid
money from her. During the years in issue, she used Dr.
Wilkinson's income to buy things that benefited her and the
family, as well as to vacation in Florida.
In September 1988, Dr. Wilkinson had gall bladder surgery.
He did not resume working until January 1989. Other than the
gall bladder surgery, Dr. Wilkinson did not have any other
serious physical illnesses during the years in issue.
Dr. Wilkinson did not undergo psychiatric evaluation during
the years in issue. He saw Dr. Coleman, a psychiatrist,
approximately 5 years after the last year in issue, for symptoms
of depression. Dr. Coleman treated Dr. Wilkinson from June 1995
through February 1996, approximately three times a month. Dr.
Coleman opined that Dr. Wilkinson suffered during the relevant
years from a personality disorder known as "double depression",
and that a symptom of this disorder is a neglect of
responsibility such as failing to file tax returns.
2. Preparation of Federal Income Tax Returns
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