Sharon Lee Bartlett, F.K.A. Heitzman - Page 44

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               That petitioner was satisfied by Mr. Heitzman’s superficial            
          explanation of the Stonehurst transaction precisely captures how            
          uninvolved she was in the family’s financial affairs.  The only             
          joint investment that Mr. Heitzman and petitioner made together             
          was their home.  Mr. Heitzman routinely made investment decisions           
          during their marriage with no participation by petitioner.  In              
          petitioner’s mind, the Stonehurst purchase was like every other             
          business transaction that Mr. Heitzman had made during their                
          marriage:  It was his property and his affair, and petitioner was           
          not privy to any meaningful information about it.  Petitioner did           
          not review any documentation such as the Stonehurst Memorandum or           
          the purchase contract or assumption agreements.  She knew nothing           
          of the substance of the transaction, nor did Mr. Heitzman discuss           
          with her any of its salient substantive aspects.                            
               While Mr. Heitzman was neither evasive nor deceptive with              
          petitioner about his investment and other financial decisions, by           
          the same token, he brooked no intrusion by petitioner into what             
          he considered his affairs.  Mr. Heitzman regarded the Stonehurst            
          purchase and his other, legitimate investments to be his, funded            
          with his money.  Petitioner had no role in deciding whether to              
          purchase the Stonehurst interest.  She also remained uninvolved             
          in subsequently claiming the deductions incident to that                    
          transaction on their 1979 joint income tax return.  In any case,            
          given the context of her and Mr. Heitzman’s marital relationship,           
          petitioner would never have expected to have had such a role.               



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