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forthright concerning the couple's income, Adams v. Commissioner,
60 T.C. 300, 303 (1973), and (3) the presence of unusual or
lavish expenditures, Mysse v. Commissioner, 57 T.C. 680, 699
(1972). Another factor the courts have focused on is whether the
couple's standard of living improved significantly during the
years in issue. Id. at 698-699.
Mrs. Streck participated in the business affairs and
bookkeeping of petitioners' businesses. During the years in
issue, Mrs. Streck was the sole shareholder of ACI. Mrs. Streck
was a signatory on ACI's bank account, and she signed checks as
an officer on behalf of ACI. She also participated in voting on
resolutions adopted by the board of directors of ACI. Mrs.
Streck was an officer of P.G.D., a corporation wholly owned by
Mr. Streck. Mrs. Streck testified that she wrote and signed
checks for all of petitioners' businesses including ACI. She
also testified she made deposits to corporate bank accounts and
paid invoices from corporate accounts. We find that Mrs. Streck
substantially participated in petitioners' combined business
affairs.
Mrs. Streck provided absolutely no evidence or argument that
Mr. Streck refused to disclose information or was not forthright
with her regarding their financial affairs.
Family expenditures during the years in issue appear to be
lavish within the meaning of Mysse v. Commissioner, supra at 699.
During 1984, through Double D Ranch, Inc., petitioners
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