Reaves Livestock, Inc., et al. - Page 52

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          substantial amounts from him in the years in issue.  Mrs. Reaves            
          points out that they had a conservative lifestyle.                          
               Mrs. Reaves benefited from the understatements on                      
          petitioners' 1984, 1985, 1986, 1987, and 1988 returns because the           
          constructive dividends were payments of her family's personal               
          expenses from the First Citizens accounts.                                  
               We conclude that Mrs. Reaves is not an innocent spouse under           
          section 6013(e) except with respect to the tax on the income from           
          the 282 checks.                                                             
               To reflect concessions and the foregoing,                              

                                                       Decisions will be              
                                                  entered under Rule 155.             

























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