- 17 -
knew that Mr. Crowley was a "commodities trader". She traveled
with him to several commodities seminars, where she attempted to
attract clients for her husband at the hospitality suites
provided by his employer after those seminars. They routinely
entertained Mr. Crowley's clients at their apartment. Petitioner
and Mr. Crowley lived lavishly during 1980 and 1981, the years
for which petitioner seeks relief as an innocent spouse. They
frequently dined at expensive restaurants during those years.
During 1980, they vacationed in 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, petitioner and Mr.
Crowley rented a two-bedroom apartment in Manhattan for
approximately $1,400 or $1,500 per month and garaged Mr.
Crowley's BMW automobile for approximately $250 to $300 per
month. Finally, there is no evidence in the record that shows
that Mr. Crowley was evasive or deceitful about their finances or
that he attempted to conceal the fact that he had engaged in
commodities straddle transactions.14 Based on the record in the
14
The Court of Appeals for the Second Circuit recently stated:
According to the dissent, the petitioner should be
deemed innocent because she is guileless and may not
have understood why * * * [her ex-husband] should have
reported his full income. This misapprehends the
nature of innocence in the context of this statute.
Innocent people pay taxes; the obligation to pay taxes
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