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she made deposits to and wrote checks on those accounts.
Furthermore, petitioner was a signatory and wrote checks on
Emmens' locksmith business account.
Moreover, there were several expenditures that appear lavish
or unusual when compared to the family's past levels of income,
standard of living, and spending pattern. The family moved to a
new house, purchased new cars, and acquired various planes and
boats which were used in the drug smuggling operation. The
Aerodrome property was paid for in cash, and some of the other
assets were paid in full. Petitioner knew the Aerodrome property
was held in a corporate name. Petitioner testified that she
believed the Aerodrome property belonged to Kadyszewski and that
he was simply being "nice" by letting the family live there rent-
free. Petitioner also testified that she believed the other
assets, including the plane Emmens was using, "just belonged to
Vince", referring to Kadyszewski. We are not convinced.
Additionally, petitioner's claim that Emmens made all of the
household financial decisions does not aid in awarding her
innocent spouse status. As we noted, a spouse's complete
deference to the husband's judgment concerning the family
finances, standing alone, is insufficient to establish that a
spouse had no reason to know. Stevens v. Commissioner, supra at
1506. Furthermore, petitioner's assertion that Emmens was
evasive and deceitful regarding the family finances and his
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