Lloyd E. Dawson, Jr. - Page 17

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          source of the income,6 he knew or had reason to know of the                 
          receipt of the income attributable to the embezzlement.  As to              
          the first factor, level of education, petitioner has presented no           
          evidence.  We note, however, that, during the years in issue,               
          petitioner was employed by Gulf States Utilities as a power plant           
          operator and control operations foreman, employment from which he           
          earned over $40,000 in 1988, and that he had been so employed               
          since 1982.  Beginning in mid-1987 and continuing through the               
          years in issue, petitioner also operated a computer consulting              
          business that included the delivery and installation of computer            
          equipment and the setting up of computerized bookkeeping and                
          payroll systems.  Certainly he had some experience in business              
          and financial matters.                                                      
               As to the second factor, involvement in the family’s                   
          finances, petitioner contends that Ms. Dawson or her mother                 
          handled his family’s financial affairs and that he was uninvolved           

          6                                                                           
               We cannot conclude with certainty from the record whether or           
          not petitioner had actual knowledge that Ms. Dawson had embezzled           
          funds from her employers when the 1988 return was signed.  For              
          instance, at trial, Ms. Dawson testified that, at the time the              
          couple purchased a motor home in 1989, petitioner told her to get           
          more money from the “agency”, i.e., her employers, so that they             
          could make a larger downpayment.  The motor home was purchased on           
          June 6, 1989, after the filing of the 1988 return in April 1989.            
          Accordingly, such testimony, even if we were to believe it, would           
          not necessarily establish that petitioner was aware in April 1989           
          that Ms. Dawson was embezzling funds from her employers.                    
          Although Ms. Dawson testified that petitioner had made similar              
          statements at other times, she could not recall specific                    
          instances.                                                                  





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