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From the time Harvey was with Dreyfus, and throughout the
relevant years, petitioners took an annual vacation at Dorado
Beach in Puerto Rico. During the years Harvey was with Dreyfus
Sales he traveled all over the world and Arlene often went with
him, but they took only one vacation a year (the vacation at
Dorado Beach) after that.
Petitioners did not maintain a joint checking account, and
Harvey took most of the responsibility for paying bills, although
he was often delinquent in doing so and, as a result, Arlene had
to confront unpaid tradesmen from time to time. Arlene had one
or two savings accounts where she deposited her earnings, but at
no time had a checking account until 1978, when Harvey gave her
one from which she could pay household expenses. Other than
this, Arlene never maintained any of the family's banking or
business records. Any time Arlene asked Harvey a question about
their family's financial affairs, his stock reply was "not now".
Arlene knew that Harvey sold tax shelters but during the
relevant years she was not privy to Harvey's business, which
Harvey refused to discuss with her, and she never went to his
office, where she was not welcome. In general, she thought a tax
shelter was something like an IRA, and therefore legitimate.
Petitioner's tax returns for many years, including the
relevant years, have been prepared by Kreindler, a C.P.A., who
was at Dartmouth College with Harvey. Kreindler is also a social
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