- 9 -
almost all the checks drawn on this account. While petitioner
and Betsy were married, petitioner deposited his earnings into
the joint bank account, and Betsy was responsible for spending
these funds. Betsy made the decisions regarding petitioner’s and
Betsy’s expenditures.
Betsy is the daughter of Harry Sley, hereinafter sometimes
referred to as Harry, and Beatrice Sley, hereinafter sometimes
referred to as Beatrice. Harry died on December 11, 1977.
During the years in issue, Beatrice generally divided her time
between Potomac, Maryland, and Miami, Florida. From about May to
November, Beatrice lived at least part of the time in a home in
Potomac, which she rented from petitioner and Betsy. From about
November to May, Beatrice lived in a Miami Beach condominium that
she owned. Beatrice died in 1991.
Betsy’s brother, Benjamin Harry Beryll Sley, hereinafter
sometimes referred to as Ben, lived in Corpus Christi, Texas,
during the years in issue. Ben is an attorney; he holds a J.D.
degree from Baylor Law School (1974) and an LL.M. in Taxation
degree from Southern Methodist University (1982).4 He was first
in his class at Southern Methodist University. From 1975 to
1979, Ben served as a judge advocate in the U.S. Marine Corps.
4 The parties stipulated that Ben received his LL.M. in
Taxation degree from New York University. Our finding, contrary
to the stipulation, is in accord with Ben’s trial testimony and
petitioner’s proposed finding, not objected to by respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011