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Petitioner had no role in Gerald's businesses. Petitioner
never went to Gerald's business offices, except on one occasion
when he was redecorating. Petitioner never attended Christmas
parties held for Gerald's employees, nor was she invited. Gerald
never discussed with petitioner the details or the finances of
his businesses. Gerald had no interest in discussing business
matters with petitioner. He considered petitioner responsible
for tending the house and caring for the children. Gerald
considered himself responsible for all matters related to his
businesses and the family's finances.
Petitioner managed a joint household checking account, to
which Gerald contributed $2,000 to $3,000 monthly, plus an amount
for the monthly mortgage payment. From this account, petitioner
paid the household expenses, such as food and utility bills.
This was petitioner's sole involvement in the family's finances.
Petitioner and Gerald (the Jacobys) led an affluent
lifestyle for several years up to and during the years at issue.
In 1973, one of Gerald's businesses acquired a pleasure boat
that petitioner occasionally used with Gerald. They owned a
residence located on 4 acres, which they purchased for $215,000
in 1976. They had a housekeeper and took family vacations, and
the children attended summer camp.
In 1979, Gerald acquired a condominium in Florida that he
used in connection with his business interests. Petitioner and
the Jacoby children visited the Florida condominium twice in
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