Linda S. Dillon - Page 15

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          ments and other financial information relating to this account              
          were received by Thomas Dillon at Dillon Securities.  Petitioner            
          admits that she did not review the 1982 Federal income tax return           
          but maintains that, even if she had, because she did not know of            
          the existence of the Murphy Favre account, she would not have               
          noticed that income from this account was not reported on the               
          return.                                                                     
               Respondent, on the other hand, points out that the account             
          at Murphy Favre was listed in the 1981 Federal income tax return.           
          Petitioner testified that Thomas Dillon always had enough money             
          at Dillon Securities to pay her credit card bills and provide her           
          with money to spend.  Although petitioner was generally aware               
          that their tax bill for 1981 was high (the Dillons paid nearly              
          $250,000 in June 1982) she also believed that Thomas Dillon had             
          enough money in various accounts at Dillon Securities to pay                
          their tax liability.  Respondent claims that this is sufficient             
          evidence of actual knowledge of the account on the part of                  
          petitioner.  Further, respondent notes that Thomas Dillon never             
          deceived petitioner or refused to discuss the family finances               
          with her.                                                                   
               Despite the fact that the Murphy Favre account was listed in           
          the Dillons' 1981 Federal income tax return, we find that peti-             
          tioner did not have actual knowledge concerning the existence of            
          the account.  Petitioner has credibly testified that she did not            





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