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and lacking in credibility. It can be drawn from the record that
petitioner’s educational background and involvement in family
financial affairs were relatively limited. However, the couple’s
accountant did testify that it was her practice to speak to both
spouses in preparing the annual return, so petitioner likely had
some familiarity with family finances. In addition, petitioner’s
involvement in the family business, as well as similar furniture
ventures, was extensive. It is also apparent that the family
maintained a standard of living sufficiently high to at least
call into question its sustainability for three persons on the
level of income reported. There is also little to suggest that
Mrs. Ishizaki was intentionally evasive or deceitful with respect
to the couple’s finances. Rather, it seems more probable that
petitioner simply chose in many instances to turn a blind eye to
the source of the funds paying the bills for a lifestyle in which
he willingly participated.
Furthermore, the testimony in this case which probes the
status of petitioner’s knowledge hardly buttresses petitioner’s
protestations of innocence. For example, during direct
examination, petitioner first testified as follows:
Q Okay. During 1995, there’s evidence that there
were checks from customers of Privilege House that were
cashed and not deposited to Privilege House. When did
you find out about that?
A When Mayra visited me.
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