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to Mr. Rowe’s separate accounts, and he did not provide her with
information regarding these accounts. Mr. Rowe opened accounts
in petitioner’s name without her knowledge and also signed
petitioner’s name on several occasions without her knowledge.
Petitioner and Mr. Rowe’s divorce was finalized in June
1996. The Final Judgment for Dissolution of Marriage between
petitioner and Mr. Rowe states that petitioner’s “standard of
living and financial circumstances have been devastated by * * *
[Mr. Rowe’s] wrong-doing and incarceration.” The final judgment
also notes that petitioner “does not have the present financial
resources to support herself and * * * [petitioners’ daughter,
Elizabeth] adequately, but that * * * [Mr. Rowe] does not have
the present ability to pay alimony.” As a result of Mr. Rowe’s
criminal activities, petitioner had to move out of the family’s
residence in Florida and back to Kingsport, Tennessee, to live
with her parents. At the time of trial, petitioner was employed
full time as a dental hygienist, and she was paid by commission
only.
For the taxable years 1987, 1988, 1989, and 1990,
petitioners filed joint Federal income tax returns which were
received by respondent on October 19, 1988, October 17, 1989,
July 31, 1991, and October 18, 1991, respectively. On June 25,
1993, respondent issued a notice of deficiency to petitioners for
their taxable years 1987, 1988, and 1989. On August 18, 1994,
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