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expenditures that appear lavish or unusual when compared to the
family's past levels of income, standard of living, and spending
pattern; and (4) the culpable spouse's evasiveness and deceit
concerning the couple's finances. Kistner v. Commissioner, 18
F.3d 1521, 1525 (11th Cir. 1994), revg. T.C. Memo. 1991-463;
Stevens v. Commissioner, supra. The foregoing factors are
considered "because, ordinarily, they predict what a prudent
person would realize regardless of the other spouse's evasiveness
or deceit". Bliss v. Commissioner, 59 F.3d 374, 379 (2d Cir.
1995), affg. T.C. Memo. 1993-390.
Petitioner did not have a college education. She never had
any formal courses in bookkeeping or accounting. She was,
however, the owner of her own business, Lake Clarke Beauty Salon.
Petitioner began at the beauty salon as a "junior operator" and
eventually purchased the business with her first husband. As
owner of the beauty salon, petitioner kept records and ensured
that tax returns for the business were filed. Petitioner managed
the beauty salon on her own after separating from her first
husband and continued to do so after she married Emmens. In
addition, petitioner also kept records for rental property which
she owned. Therefore, in considering her level of education, we
find that petitioner had a practical education in business.
Petitioner was also intimately involved in the family's
financial affairs. She had access to the family bank accounts;
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