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checking account with Texaco P.A.W. in the amount of $145,458.62.
The total amount of the checks written on both the accounts thus
exceeded $290,000. Such a level of expenditure was made possible
by the deposit in the accounts of the $153,726 that Ms. Dawson
embezzled from her employers during 1988. Although the record
indicates that petitioner may have written only a relatively
small percentage of the checks drawn on the accounts, and
petitioner claimed to have been uninvolved in his family’s
finances prior to March 1989, we do not think it reasonable to
conclude that he failed to notice that during 1988, he and Ms.
Dawson spent an amount that was two or three times (1) the amount
that he claimed to have believed to have been their income for
each of 1987 and 1988 (viz., between $90,000 to $120,000) and (2)
the amount of adjusted gross income reported on each of their
1987 and 19887 returns.
The specific expenditures disclosed by the record that were
made during 1988 also should have alerted petitioner to the
probable omission of income from the 1988 return. While the
record shows that in 1987 a Lincoln Continental automobile and a
Ford Big Bronco automobile were purchased, and a three-car garage
costing $9,700 was added to petitioner’s and Ms. Dawson’s home,
7
Petitioner has conceded that the 1988 return omitted the
following amounts received by Ms. Dawson: (1) $30,000 of wage
income from PAHHS and BHHS; (2) gross receipts of $740, and (3) a
pension distribution of $1,055.
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