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At the time of trial, petitioner was 74 years old.
Petitioner received a bachelor’s degree from Wayne State
University in 1948 and a master’s degree in education from the
University of Michigan in 1953. Petitioner worked as a first
grade teacher until her first child was born in 1955, when she
became a stay-at-home mother. Petitioner has four children who
are now adults: Nan, Karen, Robert, and Gretchen.
Petitioner married Dr. William J. Alt (Dr. Alt) in 1954, was
married to Dr. Alt during the years at issue, and is currently
married to Dr. Alt. Dr. Alt graduated from medical school at the
University of Michigan in 1953, began his medical practice in
Muskegon, Michigan, in 1959, and practices internal medicine with
a specialty in cardiovascular disease. Prior to the years at
issue, petitioner and Dr. Alt owned a 2,500-square-foot home.
From the beginning of Dr. Alt’s medical practice, petitioner
and Dr. Alt used a tax preparer, Mr. Ron Schultz (Mr. Schultz),
who was not a C.P.A. but worked with an accounting firm.
Petitioner would sign the tax returns without reviewing the
contents. In the early 1980s, Mr. Schultz retired, and
petitioner’s daughter, Karen, took over the financial affairs of
petitioner and Dr. Alt and would prepare their tax returns.
Karen’s corporation, K.L. Financial Management, was shown as the
tax preparer. Each year from 1975 through the years at issue,
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