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On July 28, 1993, Great American Federal checking bank
account No. 20374823 (the Great American Federal checking
account) was opened in the names of petitioner’s daughters,
“Bridget or Meghan Doyle”. Checks were drawn on this account
from time to time to pay petitioner and her husband’s expenses.8
The bank statements and canceled checks for this account were
mailed to petitioner’s address, where her daughter Meghan Doyle
resided. Additionally, checks made payable to the Doyles were
deposited into the Great American Federal checking account.9
On July 30, 1993, the Internal Revenue Service filed notices
of Federal tax liens against the Doyles for the tax liabilities
redetermined by this Court. Between September 18 and September
25, 1993, petitioner and her husband took a vacation to Italy at
a cost of approximately $11,000.
On September 23, 1993, petitioner’s husband liquidated an
investment interest in Colonial Properties, Inc. The proceeds of
the liquidation were received in the form of a check in the
amount of $20,900 dated September 23, 1993, and made payable to
8Petitioner’s husband explained their use of the daughters’
bank accounts at a bankruptcy creditor’s meeting: “We had our
daughter Bridget or Meghan write checks for our living expenses
* * *. Quite honestly the reason for this was because we were
worried about putting money into our account * * * and take the
chance and jeopardizing the IRS attaching that money.”
9On June 10, 1994, petitioner and her husband gave
respondent a collection statement which failed to disclose the
Great American Federal checking account.
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