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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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