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their children, took trips together to gamble in places such as
the Bahamas, Atlantic City, New Jersey, and Las Vegas, Nevada.
Over their lifetimes, Frank and Katherine made numerous
gifts to their children and grandchildren. Frank and Katherine
also gave them money and paid for some of their personal
expenses. At some time, Frank and Katherine gave their daughter
Janie jewelry valued at $22,800. Katherine also paid for the
weddings and divorces of her children and grandchildren. She
paid for vacations for her children and grandchildren and their
families. She gave them money to gamble. Katherine and Frank
also purchased U.S. Savings Bonds as birthday gifts for Larry,
Ronnie, and Sylvia. In addition, she gave them cash for asset
acquisitions, including houses, cars, and boats.
Respondent was unable to locate any record showing that
Frank or Katherine had ever filed a gift tax return.
Katherine and Frank received little or no formal education.
They had only minimal reading and writing skills and only basic
math skills.
During the years in issue, Katherine suffered from various
medical problems, including a heart condition, diabetes, vision
impairment, high blood pressure, high cholesterol levels, water
retention, and obesity. At various time during the years in
issue, she was admitted to the hospital for treatment. Her
vision was impaired due to cataracts and retinal hemorrhages;
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