William C. and Elaine Gaskins - Page 17

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          documents, petitioners denied possessing most of the documents              
          requested, items that were necessary to determine petitioners'              
          previous levels of income, their lifestyles, and whether                    
          petitioner wives benefited from the understatements.  Petitioner            
          wives produced these same documents over the period June 24,                
          1994, up to the date of, and during, the trial on August 24,                
          1994.  At the end of the first day of trial, the trial had to be            
          recessed until 1:00 p.m. the following day to afford respondent's           
          counsel an opportunity to review a full box of documents that had           
          not been produced prior to that time.  At trial, petitioners                
          provided testimony regarding petitioner wives' knowledge and                
          involvement with petitioner husbands' business and petitioners'             
          spending habits.                                                            
               Based on this testimony and a review of the multitude of               
          documents belatedly submitted, the Court concluded that                     
          petitioner wives were entitled to innocent spouse relief.  The              
          source of the Quinns' substantial accumulated savings was a                 
          critical item, particularly in view of Mrs. Quinn's obvious                 
          astuteness in financial matters.  Similarly, Mrs. Gaskins'                  
          involvement in her husband's business affairs raised credibility            
          issues not all of which were resolved by the Court in her favor.            
          Prior to the exposition of these matters at the trial, the                  
          Court's analysis of all the facts and circumstances of the case,            
          and the Court's resolution of credibility issues, it would not              






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