- 14 - Petitioner did, however, enjoy the benefits of traveling to resorts in connection with gambling activities, and some of that travel was lavish. The amount of travel was about the same, before, during, and after the tax years for which the grossly erroneous deductions were claimed. Philip's reported gross income, without considering deductions or the grossly erroneous amounts, ranged from a low of $297,982 to a high of $1,264,674 from 1981 through 1985. The record reflects that his reported income in other years was similar in amount. His income fluctuated due to the nature of his business activity--mortgage broker. That amount of income would have provided petitioners with a high standard of living without considering the tax savings generated by the tax shelter in question. A substantial portion of the tax savings was likely consumed by Philip's gambling losses. About $700,000 of tax savings is attributable to the grossly erroneous deductions generated by the subject tax shelter. During the same period, Philip's gambling activity consumed as much as $650,000. In subsequent years, Philip's gambling activity appears to have increased, and his losses also likely increased, ultimately ending in the conflict with petitioner that led to separation and, allegedly, to divorce. Our record does not reflect whether petitioner and Philip were actually divorced, but references to the divorce appear in the appellate briefs connected with this case. We are also unaware of the ultimate divorce settlement,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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