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Sometime before the spring of 1984, David began working as a
real estate investment adviser for Comstock Financial Services,
Inc. (Comstock Financial), an insurance agency owned and operated
by Roy L. Comstock (Comstock). During the spring of 1984, David
told petitioner that Comstock was investing in Hitech.
During 1984 and 1985, David maintained a business checking
account under the name Hitech. Petitioner was not a signatory on
this account. David periodically gave petitioner checks drawn on
the Hitech account and made payable to "Margaret Wiksell", which
she deposited into her two personal checking accounts. In 1984,
petitioner was given 23 checks from Hitech totaling $54,500. In
1985, petitioner received 15 Hitech checks totaling $140,500 from
Hitech.
In 1984 and 1985, petitioner wrote checks on her accounts
totaling $78,781.38 and $149,444.32, respectively. Among other
things, these checks were used for clothes; loans to a child;
charitable and political contributions; entertainment and gifts;
home furnishings; home repair and maintenance; credit card
payments; mortgage payments; and numerous other miscellaneous
expenses.
In January or February 1987, David was arrested and charged
with fraud in connection with a scam perpetrated by Roy Comstock,
Abraham Boldt, and David, wherein it was alleged that at least $2
million, fraudulently obtained from unsuspecting investors in
Comstock Financial, was diverted to Hitech. On January 13, 1988,
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