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Petitioner's husband worked as a physician during the years
in issue. Petitioner had very little involvement in her
husband's medical practice. She testified that her involvement
was limited to picking up a bank bag from her husband's office
and delivering it to the bank.
Petitioner maintained her own checking account during the
years in issue. Petitioner would pay for food, the family's
clothing, and gas for her car from her checking account. She
would also pay the family's utility bills out of her checking
account. When petitioner needed money to deposit in her checking
account, she would ask Pamela Mitchell, her husband's secretary,
to write her a check.
Petitioner did not live a lavish lifestyle during the years
in issue. She and her family lived in an old farmhouse that was
simply furnished. Petitioner maintained a social membership at
the Harlingen Country Club, but the record is unclear as to what
year the membership began. Petitioner was active in a garden
club during the years in issue. She even held the position of
secretary and president for 1 year.
Petitioner and her husband acquired several properties in
San Benito during the years in issue. During 1978 they acquired
the "East Jackson" property, the 1602 Sunshine Strip property,
the 1801 Sunshine property, and the 1045 South Commerce property.
In 1979, petitioner and her husband acquired property on West
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