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(2) the spouse's involvement in the family's business and
financial affairs; (3) the presence of expenditures that appear
lavish or unusual when compared to the family's past income
levels, income standards, and spending patterns; and (4) the
culpable spouses's evasiveness and deceit concerning the couple's
finances. See Kistner v. Commissioner, supra at 1524.
As to the first factor, level of education, petitioner
earned a college degree in medical records administration from
St. Louis University. She also owned and operated her own
construction business (JCB) that was, like the corporation in
which her husband was a shareholder (BGE), an S corporation.
Petitioner was primarily responsible for JCB's day-to-day
affairs. She collected the information with which to file tax
returns for JCB and signed those tax returns. Consequently, we
believe that she must have been familiar with the manner in which
income of an S corporation flows through to the individual
shareholders for Federal tax purposes. Although petitioner
testified that she had nothing to do with petitioner's husband's
nursery business during its existence, she admitted that she was
the secretary-treasurer of Sweetwater Greenery, Inc. (the
bankrupt predecessor company of BGE and the initial S corporation
operating the foliage nursery). By 1992, petitioner had
considerable experience in business and financial matters. At a
minimum, given her experience in the family's financial affairs,
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