Joan Walters, f.k.a. Joan Gherman, and Henry Gherman - Page 59

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          contend further that the income reported on their joint returns             
          for years ended 1984 through 1986 was sufficient to support their           
          lifestyle.                                                                  
               Respondent contends that it is not inequitable to hold Ms.             
          Walters liable for the deficiency attributable to the substantial           
          understatement, because she benefited from the income above                 
          normal support and she helped Mr. Gherman obtain the unreported             
          income through her ownership of FIP.  As examples of significant            
          benefits from the unreported income, respondent cites the Eastern           
          Shores house, the purchase and use of the Camelot, her show                 
          business endeavors, lavish gifts to her children and                        
          grandchildren, parties and other entertainment, and personal                
          investments and bank accounts.  Additionally, respondent contends           
          that Ms. Walters benefited from the embezzlement because Mr.                
          Gherman used some of the stolen funds to pay off major debts of             
          Ms. Walters, such as her automobile and Federal income tax                  
          liabilities.                                                                
               We have been provided with few specific facts relating to              
          petitioners' lifestyle, expenditures, and asset acquisitions and            
          dispositions for the years 1984 through 1986.  See Bokum v.                 
          Commissioner, supra at 157; Estate of Krock v. Commissioner,                
          supra.  To a large extent, the specific facts regarding                     
          petitioners' lifestyle, spending habits, and asset acquisitions             
          and dispositions revealed in the record relate to years before or           
          after the applicable years.                                                 



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