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of her daughters. Petitioner paid her daughters' and mother's
income tax out of her joint bank account with Philip. Philip
paid a total of approximately $15,000 for petitioner's daughter's
wedding expenses.
Petitioners had a joint bank account from which to pay
household expenses. Philip would deposit either cash or checks
into the account for petitioner to use to pay various expenses.
Petitioners also paid a variety of their expenses in cash.
Philip would give petitioner the cash to pay for groceries, dry
cleaning, domestic help, etc. The cash Philip gave petitioner
was in addition to the money he deposited in their joint account.
Philip also had several individual bank accounts.
Petitioners' recreation was combined with gambling. They
went to Las Vegas, Nevada, on their honeymoon and took other
vacations where gambling was a focal point, such as their annual
trip to Puerto Rico. Philip would go on day trips to Atlantic
City, New Jersey, or take weekend trips to Las Vegas, Nevada.
Petitioner would occasionally accompany Philip on the weekend
trips, or they would both go with their good friends Adrienne and
Elwood Lerman (Lerman). Lerman was also petitioners' accountant
and financial adviser. Some of these gambling trips would be
"comped"; i.e., the casino would pay for travel, meals, and hotel
room.
While on these trips, Philip would spend most of his time
gambling in the casinos. He usually played at the craps table
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