- 3 -
(6) whether petitioner is liable for the additions to tax for
substantial understatement of tax under section 6661 for 1985,
1986, and 1987.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Holmdel, New Jersey.
A. Background
Petitioner and her husband have known each other for most of
their lives; they grew up across the street from one another in a
lower middle class neighborhood in Hoboken, New Jersey.
Petitioner married Mr. Acquaviva in 1960 at the age of 17. Mr.
Acquaviva was the breadwinner; petitioner was a housewife who
stayed at home to take care of their four sons. Mr. Acquaviva
was a residential real estate developer and, during the 1986 and
1987 taxable years, an officer-shareholder in Magnum. Petitioner
and Mr. Acquaviva enjoyed a harmonious and close family
relationship with each other and their sons.
Shortly after they were married, the Acquavivas moved into a
tenement apartment in Hoboken, New Jersey. The couple's standard
of living improved throughout their marriage as Mr. Acquaviva's
businesses prospered. By the early 1980's, the family lived in a
large five-bedroom home, which Mr. Acquaviva built, in an upscale
neighborhood located in Holmdel, New Jersey. The couple had a
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011