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never examined the bank statements because it was Mr. Aude's job
to review the bank statements.
Petitioner played a minimal role in the tax preparation of
her and Mr. Aude's returns. While petitioner prepared a summary
of the household expenditures for Mr. Gruys, she was generally
not present when Mr. Aude furnished his information to Mr. Gruys.
Mr. Gruys primarily talked with Mr. Aude, and only occasionally
talked with petitioner, usually when petitioner submitted her
list of expenditures.
The third factor we consider is the presence of lavish or
unusual expenditures by the family. Examining the record, there
were no major differences in the Audes' standard of living
before, during, or after the period in which these deductions
were claimed. First, petitioner received a monthly allowance,
which was used to care for five children and the other household
expenses. While the allowances at times decreased during the
years at issue, they never increased. Petitioner did not buy any
jewelry or expensive clothes during this period, and she drove a
1980 station wagon. During the 3 years at issue, the Audes only
took one vacation in December of 1982. Further, during the years
at issue, petitioner and Mr. Aude lived in the same house, which
they purchased in 1978. They had built an addition to that house
in 1978-79. Taken together, these expenditures do not amount to
unusual, lavish, or extravagant expenditures.
The fourth factor is whether Mr. Aude was evasive or
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