Philip H. and Anna Friedman - Page 8

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            The reconstruction is, to some extent, overstated because some of                              
            the source documents were shown not to reflect gambling                                        
            expenditures.  In addition, it has not been established that the                               
            amounts reflected were expended solely for gambling.  The                                      
            expenditures do not reflect the source of the funds expended.                                  
            Some of the funds may represent winnings, and some may represent                               
            Philip's and petitioner's cash-flow from other income, tax                                     
            savings, or other sources.                                                                     
                  Petitioner was aware that Philip was an avid gambler both                                
            when she married him and during their marriage.  During the years                              
            in issue, petitioner was not aware of the full extent of Philip's                              
            gambling expenditures.  Philip wrote checks and depleted both his                              
            and the couple's checking accounts to the point where checks on                                
            the account used by petitioner for household matters were                                      
            returned because of insufficient funds.  By 1990, petitioner and                               
            Philip argued, and their relationship deteriorated due to                                      
            Philip's gambling and the overdrawn accounts.                                                  
                  Petitioner's and Philip's joint income tax returns for the                               
            taxable years 1981 through 1985 reported income in the amounts of                              
            $297,982, $595,375, $216,932, $660,892, and $1,264,674.  The                                   
            income tax deficiencies determined by respondent for the taxable                               
            years 1981 through 1985 are as follows:                                                        









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