Mark N. and Marla R. Kantor - Page 7

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            which his employers withheld Federal and State income and                                 
            employment taxes, were petitioners' sole source of support.3  In                          
            the years 1981 to 1985, Mark earned gross income of $129,962,                             
            $199,407, $442,517, $243,373, and $317,538, respectively.  At                             
            home, Marla focused on keeping an air of normality about her life                         
            and that of their children by paying the bills and performing                             
            other essential tasks, even as she denied the increasing severity                         
            of Mark's drug use problem and feared to confront him about it.                           
                  Petitioners' family spending pattern remained relatively                            
            constant throughout the years in issue.  However, the record of                           
            their year-by-year expenditures is fragmentary because checks,                            
            check registers, and other records are missing for tax years 1981                         
            and 1985.                                                                                 
                  The record shows that Mark and Marla habitually used cash                           
            for much of their consumption during the entire period of 1981 to                         


                  3Mark's employers only withheld a portion of the taxes owed.                        
            Petitioners paid substantial additional amounts of taxes due for                          
            each year when they eventually filed their delinquent returns on                          
            Aug. 26, 1987:                                                                            
                                               Amount                  Additional                     
                      Year                    Withheld                 Tax Owed                       
                      1981                    $28,159                   $7,934                        
                      1982                    42,891                    23,421                        
                      1983                    113,351                   61,862                        
                      1984                    57,177                    25,384                        
                      1985                    71,533                    43,596                        





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