Diane S. Blodgett - Page 3

                                        - 3 -                                         

          owned 27.5 percent of the business.  The children of petitioner             
          and Mr. Blodgett, Michael J., Matthew, and Christina, each held             
          15 percent of the business.  The record is silent as to                     
          petitioner’s participation in the business.                                 
               The business had a defined benefit pension plan, the T.G.              
          Morgan Defined Benefit Pension Plan (pension plan).  However, the           
          record is not complete with respect to the formation,                       
          administration, and records of the pension plan.  Insofar as the            
          record reveals, its activity was not reported to the Internal               
          Revenue Service on Form 5500-EZ, Annual Return of One-Participant           
          (Owners and Their Spouses) Retirement Plan.  Petitioner                     
          introduced at trial an unfiled Form 5500-EZ relating to the                 
          pension plan.                                                               
               Through the financial success of the business, petitioner              
          and Mr. Blodgett were able to lead a lavish lifestyle.  In 1989,            
          Mr. Blodgett purchased an original Simbari oil painting for                 
          petitioner for $85,000.  Petitioner admired the artist, and the             
          painting was displayed in petitioner’s home.  In 1990, petitioner           
          and Mr. Blodgett purchased a condominium and lot at Key Largo,              
          Florida (Florida property).  They bought furniture and had it               
          shipped to the property.  They never occupied the property, nor             
          did they rent it out for any period of time.   They visited the             
          property once, as Mr. Blodgett stated, “to tour it”.                        







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  Next

Last modified: May 25, 2011