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above income tax deficiencies and additions to tax. At the time
petitioner filed her petition, she resided in Kings Point,
New York. On September 28, 1994, an Order and Decision was
entered with respect to Martin's petition, wherein the Court
found that Martin was liable for all income tax deficiencies and
all additions to tax determined by respondent.
Martin's and Petitioner's Education and Business Activity
Martin has a bachelor’s degree in public accounting, a
master's degree in public administration, and a Ph.D. in
accounting. Martin has been a college professor of economics, a
financial consultant, an investment adviser to a pension plan,
owner of at least seven real estate and leasing business
ventures, owner of a Roy Rogers restaurant franchise, and,
generally, a wealthy businessman.
Throughout most of the 1970's and 1980's, Martin controlled
numerous stock brokerage accounts in his individual name, in
petitioner's individual name, and in his and petitioner’s joint
names. Martin annually engaged in numerous stock transactions
involving hundreds of thousands of dollars.
Petitioner has a college degree and a master's degree in
speech pathology and audiology. Except for a brief teaching
career and an occasional job as a substitute teacher, petitioner
has not worked outside the home, and petitioner’s primary
occupation has been as a mother and homemaker.
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