- 5 -
could spend; if she needed additional funds, she simply asked her
husband to deposit more money into their joint account.
Petitioner's education ended with high school. Petitioner
had no training or background in accounting, business, or
finance, with the exception of running a retail clothing business
called "Unique Boutique", which Mr. Acquaviva set up as an
amusement for her.3 Petitioner's participation in her husband's
business was limited to decorating some of the model houses which
he built. Petitioner was otherwise unemployed during the
relevant years.
B. Mr. Acquaviva's Business Activities
During the years in issue, Mr. Acquaviva did not conceal his
business activities or the family's financial affairs from
petitioner. However, Mr. Acquaviva generally did not discuss his
investments or the family's financial affairs with petitioner.
Mr. Acquaviva usually did not conduct business at home.
Petitioner did not question her husband's decisions. Petitioner
trusted her husband and believed he would do what was best for
the family.
Shortly after his marriage to petitioner in 1960, Mr.
Acquaviva took over his father's refrigerator repair service. He
3 Although petitioner was the owner/operator of this dress
shop, she left all of the business decisions to her husband.
During the 4 years that petitioner's dress shop was in operation
from 1982 through 1985, the business incurred a net loss of
$27,455.
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