- 56 -
As to the third factor, unusual or lavish expenditures, the
record demonstrates that the family did not enjoy a high standard
of living during the years at issue. Indeed, the cash they had
accumulated was consumed. Barbara paid for her college tuition
with a student loan and maximized her credit card. She and
Raymond lived in the same house for more than 21 years; they
bought only inexpensive used cars; they refinanced their house,
and their children paid for their own educations. Most of
Raymond's income was applied toward acquiring collectibles; only
a small portion was spent for the benefit of the family. There
is no evidence in the record indicating any expenditures out of
the ordinary when compared to petitioners' spending habits in
prior years.
As to the fourth factor, there is no evidence that Raymond
ever attempted to hide any of his income or assets from Barbara.
Barbara was aware that Raymond was depositing substantial
amounts of money into their personal checking account, she knew
of her husband's sports memorabilia activities and that he often
dealt in cash during the years in issue. Barbara, however, had
no knowledge or reason to know that his net income from those
activities during those years exceeded the amounts reported on
the returns.
We reject the importance that respondent places on Barbara's
access to the National City Bank account. Checks written on that
Page: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 NextLast modified: May 25, 2011