- 59 - 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.Page: 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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