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shelter deductions.13 Petitioner testified that the refund
checks were deposited into the family checking account to “Do the
household things we wanted to do.” Additionally, the parties’
stipulation that petitioner and her husband enjoyed two vacation
trips to Europe immediately after this Court’s decision that the
couple owed significant amounts of Federal income tax weighs
heavily against her.
In determining the equity of the sought-after relief, we
also find it significant that petitioner and her husband tried to
thwart respondent’s collection activities. The record
demonstrates that after this Court sustained respondent’s
deficiency determinations, petitioner and her family engaged in a
systematic plan to put their assets beyond the reach of
respondent’s legitimate collection activities. Petitioner and
her husband encumbered their personal residence, which they had
previously owned lien free. The proceeds of the mortgage were
immediately converted into cash and cash equivalents and spread
among petitioner’s children by deposit into freshly opened bank
accounts in the children’s names. Petitioner and her husband
liquidated investments and transferred the funds to their
children. The children used transferred funds to pay their
13By their very nature, the erroneous deductions provided
the Doyles with more disposable income than they otherwise would
have had. For example, the Doyles “sheltered” approximately 69
percent of their 1980 income.
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