3
Prior to the years in issue, petitioner Rosemarie Wolfe was
married to Jose Escalante, on two separate occasions, and they
have three children. During the years in issue here, however,
Jose Escalante was married to Susan Escalante (now Susan Myers).
During the years 1984, 1985, and 1986, Susan Escalante was
employed by the Spring Branch Savings & Loan Association in Texas
as a branch manager. She was not a loan officer. Nevertheless,
during that period she abstracted large amounts of money from the
savings and loan association (hereinafter Spring Branch), and
during the years in question caused the following amounts of
money to be transferred, with their complicity, to one or both of
petitioners, or to others who in turn remitted the money to one
or both of petitioners:
1984 1985 1986
$100,000 $512,000 $199,278
All the above proceeds were received by petitioners or
deposited in a bank account or bank accounts controlled by them.
Petitioners were also the sole owners of and controlled the
business known by the name of Deli, Etc., in Cypress, Texas, and
controlled bank accounts of that organization.
Susan Escalante later pled guilty to both criminal and civil
charges in connection with these abstractions, inter alia, from
Spring Branch. Upon audit, respondent's statutory notice
increased petitioners' income by the above amounts, after giving
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