William C. and Elaine Gaskins - Page 46

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            Occasionally, she wrote out West Pine checks under Mr. Quinn's                                 
            direction, for his signature. What knowledge she had of West                                   
            Pine's activities was limited to information gathered from this                                
            ministerial duty. As underscored by Mrs. Quinn's strong                                        
            emotional reaction to recalling the events related to the Credit                               
            Alliance suit, even after the passing of 12 years, she had-no                                  
            awareness of any of Mr. Quinn's business activities that would                                 
            give rise to personal liability prior to her discovery of that                                 
            matter in June of 1982, after the years involved in this case.                                 
            Up until that time, Mrs. Quinn had trusted Mr. Quinn and had no                                
            reason to question his actions. See Pietromonaco v.                                            
            Commissioner, 3 F.3d 1342 (9th Cir. 1993), revg. T.C. Memo.                                    
            1991361 and T.C. Memo. 1991-472 (Supplemental Opinion).                                        
            Moreover, even if she had learned of the Credit Alliance matter                                
            before the filing of their 1981 individual tax return, that                                    
            would not have alerted her to the possibility that Mr. Quinn had                               
            received unreported income from West Pine. If anything, that                                   
            lawsuit, plus Mr. Quinn's apparent failure to receive his                                      
            regular paychecks from West Pine, would have suggested that West                               
            Pine had no money, not that Mr. Quinn was diverting corporate                                  
            receipts.                                                                                      
                  Mrs. Quinn has maintained a moderate lifestyle, with no                                  
            lavish expenditures. For most of her married life, she has lived                               
            in the house purchased and occupied by her parents. She and her                                
            husband have worked their entire adult lives, regularly setting                                




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