Joan Walters, f.k.a. Joan Gherman, and Henry Gherman - Page 53

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          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 her             



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