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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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