Evelyn M. Martin - Page 5




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          connection with the corporation’s public image.  Petitioner was             
          able to pick up a limited amount of business information from her           
          participation on the boards of some of the related corporations,            
          but she was generally not involved in or knowledgeable about the            
          day-to-day operations or the details of the business of                     
          Financial.                                                                  
               Mr. Martin’s success in the insurance business permitted the           
          Martins, during 1975, to build a palatial home in the Sweetwater            
          Estates subdivision.  From 1975 through 1986, the success and the           
          quality of the Martins’ lifestyle continued unabated, including             
          the purchase of Rolls Royce and Lamborghini automobiles, a 60-              
          foot yacht, several other luxury automobiles, 2 airplanes, 5-               
          carat and 12-carat diamond rings given to petitioner as gifts by            
          Mr. Martin, and 4 Rolex watches.  Although the Martins reported             
          some net Federal income tax losses during the period 1981 through           
          1986, it was not uncommon for Mr. Martin to receive Forms W-2 for           
          amounts in excess of $1 million.  The Martins employed several              
          household staff members and a full-time gardener.  Petitioner was           
          involved in high profile charitable and political fund raisers              
          and threw lavish parties at the Martins’ home.  Although                    
          petitioner was a member of several of the corporate boards and              
          was involved in the publication of Central Florida Magazine,                
          during the period 1973 through 1987, she was primarily a                    
          housewife and mother.                                                       






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