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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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