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son's graduation and one for $350 for the support of his wife and
their two youngest children.
During calendar year 1993, petitioner received taxable wages
in the amount of $18,202 and taxable unemployment compensation in
the amount of $4,810. During calendar year 1993, petitioner made
seven wire transfers to Peggy Layman totaling $2,700 for the
support of his wife and their two youngest children.
Consequently, petitioner provided a substantial portion of the
net income for the benefit of Peggy Layman and their dependent
children during 1991, 1992, and 1993.
Respondent also alleges that the fluctuation in the amounts
petitioner sent to his former spouse for her support and the
support of their children in 1991, 1992, and 1993, is further
indication that petitioner acted as though he were solely
entitled to the income. Respondent places too much emphasis on
the fact that petitioner determined the amount of money, if any,
that he would send to Peggy Layman for her support and the
support of their children. Petitioner consistently sent funds to
his wife throughout 1991, 1992, and 1993. Petitioner sent Peggy
Layman 15 wire transfers in 1991 throughout 9 months, 24 wire
transfers in 1992 throughout all 12 months, and 7 wire transfers
in 1993 during the first 3 months of 1993.
During 1991, petitioner sent Peggy Layman $3,450 in January,
$2,200 in February, and $1,500 in April; from August through
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