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contends, section 6013(e)(1)(B) is satisfied because the omitted
income came solely from her then-husband's narcotics trafficking.
Petitioner's testimony that she was completely unaware of
her then-husband's narcotics trafficking is implausible.
Respondent's witness, Sydoriak, testified as to petitioner's
function in the drug smuggling operation. At trial, Sydoriak
indicated that petitioner helped outfit the boats with food
supplies for the drug runs. Once the boats were underway,
petitioner also assisted in monitoring radio transmissions.
Furthermore, Sydoriak testified regarding specific instances
where petitioner was directly handling large sums of cash and
drugs.
Although Sydoriak was not an irreproachable witness, we find
that his testimony was credible. Sydoriak had extremely detailed
knowledge of the operation in general and had no incentive to
testify other than truthfully.
Moreover, based on petitioner's testimony, we find it highly
unlikely that she had no involvement in the operation and was
completely unaware of the narcotics trafficking until 1988.
Petitioner testified that she flew to Paris on the Concorde in
1985. Petitioner claimed that she did not pay for her ticket,
but flew there with a girlfriend who had bought a ticket on a
"buy one-get one free" arrangement. Petitioner testified that
she thought her girlfriend was just being "nice". While in
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