- 41 - horses in the possession of the Shortinos. Christopher testified that petitioner was not involved in the horse activity and that she did not make any decisions relating to the activity. Mr. Rowe testified that he made the original decision to start the horse activity and that he did not discuss it with petitioner. Mr. Rowe considered the activity principally his, and he included his children in the activity. Mr. Rowe testified that he made all decisions regarding the horse activity and told petitioner nothing about the horse activity. Additionally, Mr. Rowe testified that he did not consult petitioner before starting the fish activity, and he did not believe she wrote any checks in connection with the fish farm. With respect to the fact that petitioner’s name was listed as a proprietor on the 1987, 1988, and 1989 tax returns, Mr. Rowe testified that the 1987 and 1988 returns were filled out by another individual and he simply signed them without reviewing their contents. As we have mentioned previously, the record indicates that petitioner was given the first two pages only of the tax returns when signing the returns, and she was not afforded the opportunity to see or review any attachments, schedules, or other documents pertaining to the returns. The Shortinos testified that the checks they received for their services as horse trainers while employed by Mr. Rowe always came from him and never from petitioner. Our review ofPage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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