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hospitality suites provided by Mr. Crowley's employer after those
seminars. Petitioner, however, did not discuss commodities
straddle transactions during the seminars or in the hospitality
suites.
When petitioner and Mr. Crowley were first married, they
rented a one-bedroom apartment in Manhattan. During their
marriage, petitioner and Mr. Crowley regularly entertained Mr.
Crowley's clients at their apartment, and they frequently dined
out at expensive restaurants in Manhattan. During 1980, Mr.
Crowley and petitioner took vacations to Canada, Vermont, and
Florida. Mr. Crowley's American Express bill for that year was
approximately $90,000, and a substantial portion of that amount
was charged by petitioner. During 1981, they moved to a two-
bedroom apartment which they rented for approximately $1,400 or
$1,500 per month and garaged Mr. Crowley's BMW automobile for
approximately $250 to $300 per month. Subsequently, they rented
a ranch house on Long Island.
During 1982, petitioner and Mr. Crowley decided to separate.
After their separation, petitioner moved into a small loft
apartment and paid the security deposit with $2,000 which Mr.
Crowley had given her. On August 18, 1983, petitioner and Mr.
Crowley were divorced.
On June 15, 1980, petitioner and Mr. Crowley signed a joint
tax return for taxable year 1979, which was filed on June 24,
1980, and reported a negative adjusted gross income in the amount
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