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Accu-Data account during 1987 and (2) the $26,080.63 of excess
funds derived from the bank accounts of Accu-Data, Trust 768,
Meadows, and MCIC during 1988 that were received by or were
expended on behalf of petitioner during those years were funds
that Mr. Morris embezzled from John Kenny Company or that further
investigation was warranted into the source of those funds.
Although petitioner was responsible during the years at
issue for handling the family finances and although she deposited
checks and other funds, some of which were derived from the bank
accounts of Accu-Data, Trust 768, Meadows, and MCIC, into the
joint checking and/or savings accounts and used the funds in
those accounts to pay the family bills, Mr. Morris took affirma-
tive steps to deceive petitioner and otherwise to prevent her
discovery of the embezzled funds. And he was successful not only
in deceiving petitioner, but also in deceiving John Kenny Company
from which he had been embezzling funds throughout a period that
commenced several years prior to the years at issue and that
continued throughout those years. Indeed, it was not until
around late January 1991, well after petitioner signed the joint
return for each of the years at issue, that petitioner and John
Kenny Company even discovered Mr. Morris' prior embezzlement
activities.
Mr. Morris spent evenings and many weekends away from home
at an office in an apartment complex and led petitioner to
believe that he was working while away from home not only for
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