John A. Rowe and Donna L. Rowe - Page 41




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          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 of              






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