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          as they always had a beautiful home and a good car, they always             
          ate well, and they always went to good restaurants.  She believed           
          that the only extravagance in their lives was the purchase of the           
          Camelot.  Ms. Walters believed that the income reported on their            
          income tax returns was sufficient to support their standard of              
          living.                                                                     
               Mr. Gherman was considered extravagant in his use of money.            
          Petitioners entertained FIP's clients and friends at their home             
          at least five times each year.  On occasion, petitioners gave               
          shopping sprees for relatives at grocery stores and at least one            
          department store (Macy's).  The department store shopping spree             
          was a Mother's Day gift for Shari and a few other relatives, but            
          Ms. Walters was not one of the shoppers.                                    
               Dating back to 1965, petitioners had a history of making               
          gifts.  Petitioners together made gifts to Shari, Craig, Chasyn,            
          and Ashtyn.  During 1983 through 1987, petitioners made gifts of            
          $20,000 each to Shari, Craig, and Chasyn.  During 1986 and 1987,            
          they also made gifts of $20,000 to Ashtyn.  Petitioners signed              
          joint gift tax returns for various years on which they reported             
          that gifts had been made to their children and grandsons.  The              
          Internal Revenue Service (IRS) has no record of any gift tax                
          returns filed by petitioners for any year.  Nonetheless, the                
          record shows that the IRS had received gift tax returns from                
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