Estate of Raymond E. Jones, Deceased, Dorothy J. Jones, Independent Executrix, and Dorothy J. Jones - Page 21

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          different cases.  Bliss v. Commissioner, 59 F.3d 374, 378 (2d               
          Cir. 1995), affg. T.C. Memo. 1993-390.                                      
               In the instant case, petitioner ran her own businesses,                
          having started them prior to the year in question.  She expanded            
          them successfully during, and after, 1981.  She handled the                 
          buying and selling of the inventory, purchased a building out of            
          which the businesses were operated, and paid the mortgage.  She             
          operated her businesses independently of Mr. Jones in spite of              
          her lack of formal education.                                               
               Because Mr. Jones traveled extensively and for long periods            
          of time, petitioner managed the family and household finances.              
          Petitioner also managed the Joneses’ monthly bills and large                
          expenditures, freely transferring funds between accounts to do              
          so.  The evidence shows that petitioner managed most of the                 
          family money, except for Mr. Jones’ expense account.  Petitioner            
          demonstrated by her testimony that she kept track of Mr. Jones’             
          earnings and where they went.  Petitioner knew about many of Mr.            
          Jones’ investments and asked about others.                                  
               Petitioner testified that she saw at least part of the 1981            
          return that she signed and that she also saw the amount of the              
          refund claimed.  She also testified that the amount of the refund           
          claimed on the 1981 return was very large compared to the                   
          overpayment claimed on the 1979 return and the tax shown as due             
          on the 1980 return.  She signed the 1981 joint return just below            
          the place on the return which reflected the unusual overpayment             




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