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Mr. Sharer was a certified public accountant. Beginning in
1980, he operated as a sole proprietorship an accounting business
known as Sharer Accountancy. During 1987, petitioner helped her
husband with his accounting business.
Sharer Accountancy maintained one bank account throughout
1986 and 1987, and another bank account from November 1986
through the end of 1987. Petitioner had authority to write
checks on both these accounts.
Throughout 1986 and 1987, petitioner and Mr. Sharer also
maintained a joint personal checking account. This account was
in the name of "Michael E. Sharer or Mary Lee Sharer".
Petitioner deposited her wages into the account, and Mr. Sharer
deposited his draw from his accounting business into the account.
Although petitioner and Mr. Sharer were not living together,
from early 1986 until about the time of Mr. Sharer's death in
1988, they represented to Mr. Sharer's accounting clients and
others, including Mr. Sharer's secretary, Sandra Matsko, that
they were still living together.
Petitioner received from Sharer Accountancy amounts marked
"spousal wages", of $1,500 for 1986 and $25,950 for 1987.
Petitioner was paid substantially all of these funds by checks
that were drawn on the Sharer Accountancy accounts; each of the
checks was annotated "spousal wages". She or Mr. Sharer made
this notation on the checks. A $9,555 portion of the funds
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