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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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