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of the $185,361 correct 1981 tax liability (supra note 2) was not
paid by or withheld from Nancy and Sheldon.
The tax refund check for 1981 was taken by Sheldon,
deposited into one of Sheldon's individual checking accounts, and
spent by Sheldon, all without Nancy's knowledge. That checking
account balance fluctuated substantially; money flowed in and out
in large amounts. See supra table 4.
How Sheldon spent this money (plus the $56,628 that he
avoided payment of) is unclear, but Nancy's lifestyle did not
change on account of the receipt of this refund and the avoided
payment. We note that throughout their marriage Sheldon and
Nancy had a comfortable lifestyle easily supported by Sheldon's
earnings. See supra table 2. Up to the time of the 1981 tax
return, Sheldon was a successful businessman who made a
considerable amount of money. Sheldon's and Nancy's lifestyle
included a New Jersey home, two cars, furs, jewelry, dining out,
going to the theatre, and taking vacations.
Sheldon also gambled and invested. During 1981 and 1982
Sheldon spent $100,000 to invest in State Coal. At the time of
his death he owed $84,000 to casinos. Sheldon owned racehorses,
and he gambled on these horses. After Sheldon's death Nancy
spent over $40,000 to wind up Sheldon's horse business.
Sheldon was a "key man" in Dawn Joy, and he had open heart
surgery at age 34; he owned much life insurance. Substantially
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