Gerald Jacoby and Arlene Jacoby - Page 4

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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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