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jointly liable for the mortgage and responsible for making the
payments on that obligation.
Petitioners went on an annual, week-long vacation to Puerto
Rico and, occasionally, petitioner's daughters would go with
them. Petitioner and Philip went on numerous gambling trips
together. On some of those trips, petitioners' room, food,
beverage, entertainment, and sometimes transportation (i.e.,
airfare) were paid for by the casino. Although petitioner did
not gamble much, she did obtain the benefit of the amenities
provided by the resort or casino. Philip gave petitioner a
diamond wedding band, but petitioner did not receive much
additional jewelry during their marriage. During April 1986,
Philip purchased an automobile for petitioner at a cost of almost
$14,000. Petitioner had a VISA credit card and other credit
cards for major New York City area department stores, including
Saks Fifth Avenue, Bloomingdale's, Fortunoff, A&S, and Macy's.
During the years in issue, petitioner obtained a black mink coat.
She also enjoyed the theater and attended many shows.
Petitioner's daughters' tuition and some expenses for
private school education, tutoring, and college were paid for by
Philip. Philip paid for food, clothing, and other expenses for
petitioner's daughters, including the acquisition of an
automobile for one of the daughters. During 1983, petitioner
transferred stocks and bonds with a $20,000 value from her and
Philip's joint account with Merrill Lynch to the account of one
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