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from Mr. Rowe’s business, and the walls were decorated with arts
and crafts which were handmade by petitioner.
While petitioner was primarily responsible for the household
duties, Mr. Rowe controlled all aspects of petitioners’ financial
matters. Mr. Rowe regularly prepared petitioners’ joint tax
returns, occasionally with the assistance of other individuals.4
During the years in issue, petitioners maintained a joint
checking account (NCNB account) at NCNB National Bank. Deposits
totaling approximately $624,286, $383,557, $26,176, and $7,086,5
respectively, were made into the NCNB account in 1987, 1988,
1989, and 1990. Mr. Rowe deposited money into the NCNB account
at irregular intervals and in amounts necessary to cover
household expenses. Petitioner and Mr. Rowe both wrote checks on
the NCNB account. The majority of the amount paid by checks from
the NCNB account in 1987 and 1988 was related to the purchase of
property and the construction of a residence thereon, and the
checks were written by or at the direction of Mr. Rowe.
Mr. Rowe also maintained separate bank accounts which
petitioner was unaware existed. Petitioner did not have access
4Richard Danley (Mr. Danley), an accountant, assisted Mr.
Rowe in preparing petitioners’ 1990 Federal income tax return.
5Approximately $4,102 of the deposit total for 1990
represented petitioner’s earnings from her employment as a
substitute teacher.
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