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substantial unexplained increase in the family's standard of
living; and (4) the conduct of petitioner's husband in concealing
the true state of the family's finances. Hayman v. Commissioner,
992 F.2d 1256, 1261 (2d Cir. 1993), affg. T.C. Memo. 1992-228.
a. Education
Petitioner possessed only a high school education.
Petitioner lacked meaningful business experience and knowledge
pertaining to finances or tax return preparation.
b. Family Business
Petitioner's knowledge of the family's financial affairs and
her husband's business affairs was minimal. Petitioner's
participation in her family's financial affairs was limited to
access to the couple's joint bank account which she used to pay
incidental household and family expenses.7 Mr. Acquaviva
dominated the couple's financial affairs throughout their
marriage. Mr. Acquaviva completely insulated petitioner from the
family's financial picture as well as his business activities.
We are convinced that petitioner had no voice in the family's
financial and business decisions. Petitioner was not in a
position to know how much income her husband generated from his
7 Cf. Price v. Commissioner, 887 F.2d 959, 965 (9th Cir.
1989) (wife had limited involvement in family finances despite
responsibility of paying mortgage); Hinds v. Commissioner, T.C.
Memo. 1988-426 ("innocent spouse" relief allowed for wife whose
participation in family's financial affairs was limited to
accepting money from husband to pay household expenses and
purchase family's food and clothing).
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