- 52 -
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.
Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Last modified: May 25, 2011