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issue. We concluded that petitioner has failed to satisfy her
burden of proof as to this factor with respect to both taxable
years at issue. In taxable year 1990, the couple acquired more
than $95,000 of depreciable assets for their farming operation.
Among the assets purchased were at least 19 head of livestock, a
Ford truck, two trailers, and two tractors. Whether such
purchases are to be considered lavish and unusual for
petitioner's household is obviously a question of fact, as "one
person's luxury can be another person's necessity, and the
lavishness of an expense must be measured from each family's
relative level of ordinary support." Sanders v. United States,
509 F.2d at 168. But we are unable to make a proper assessment
of the asset acquisitions involved in this case because the
record lacks evidence against which an appropriate comparison can
be made. Perhaps petitioner and her former husband routinely
acquired large quantities of livestock, as well as multiple
vehicles and farm equipment, but nothing in the record suggests
this to be the case. In fact, petitioner does not even argue as
much.
Similarly, with respect to taxable year 1991, other than
petitioner's general denial, as noted above, the record lacks
evidence of whether petitioner and her former husband made
unusual or lavish expenditures, or experienced significant
changes in lifestyle. Persuasive evidence would have been
relatively easy for petitioner to provide, yet she elected not to
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