Barbara A. Vriner, A.K.A. Barbara A. Coyne - Page 3

          Vriner would bring money home from the Vriner restaurant, and               
          occasionally he would bring home groceries such as eggs, milk, or           
          lettuce.  Petitioner was employed as a dental receptionist.                 
               On their 1987 joint return, the Vriners reported on Schedule           
          E rental income and expenses from real estate.  Mr. Vriner told             
          petitioner that he owned the rental property with his brother,              
          but petitioner knew little else about the property.                         
               By 1987, the Vriners had closed their joint checking account           
          because, when Mr. Vriner would take the checkbook to the Vriner             
          restaurant, members of the Vriner family would write checks on              
          the account.  After closing the checking account, petitioner paid           
          their bills either in cash or with a money order.                           
               Mr. Vriner leased a car and told petitioner that he would              
          take care of the payments in the amount of $266.84 per month.  In           
          June 1987, petitioner's father gave petitioner a 1977 Pontiac               
          Bonneville.  The Vriners had one child, and once or twice during            
          their marriage they traveled to California to visit petitioner's            
          parents.  They rarely traveled on weekends or went out to dinner.           
          Mr. Vriner purchased no expensive items for the home.                       
               In 1988, Federal agents conducted a search of the Vriners'             
          home.  During the search, petitioner learned that her husband was           
          under investigation for narcotics activities.  No narcotics were            
          found during the search, and petitioner had no knowledge of her             
          husband's narcotics activities prior to the search.  Although Mr.           
          Vriner had prior arrests for driving under the influence, those             

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