- 53 - the high amount of gross income reported on the returns caused Ms. Walters to assume that their reported income was sufficient to support their standard of living. Furthermore, petitioners began moving up into better homes and neighborhoods, had household help, threw elaborate parties, and otherwise enjoyed a fairly high, and generally improving, standard of living years before Mr. Gherman began embezzling money from FIP's clients. The house in which petitioners lived during the years in issue was purchased in 1981 or 1982, before that Mr. Gherman began embezzling money from FIP's clients. Mr. Gherman made all decisions relating to financial matters that affected both FIP and petitioners. Except for some minor household expenditures that were paid out of the Joan Gherman No. 1 account, Mr. Gherman or a member of his office staff paid petitioners' personal bills from the FIP account or the Joan Gherman No. 2 account. Ms. Walters signed checks drawn on those accounts in blank. Furthermore, she did not balance any of the checking account statements. Consequently, we are persuaded that Ms. Walters had no reason to suspect that their lifestyle exceeded their reported income, if it did. See Sanders v. United States, 509 F.2d at 168. Respondent contends further that Ms. Walters' show business activities demonstrate that she lived extravagantly during 1984 through 1986. The show business activities addressed at trial, e.g., her producing "Purlie" and "Bubbling Brown Sugar" and herPage: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 Next
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