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1998. At that time, petitioner was also receiving child support
from her son’s father.
Petitioner and her former husband, William K. Elesh, were
married in 1991. Shortly after marrying Mr. Elesh, petitioner
moved with him from Illinois to Wisconsin. During their
marriage, petitioner and Mr. Elesh maintained separate bank
accounts and credit cards, and petitioner was not included in any
of the financial matters conducted by Mr. Elesh, such as the
purchase of their family home. During the years in issue, Mr.
Elesh was an engineer and was employed as an executive, earning
approximately $100,000 per year. Petitioner was responsible for
purchasing certain household needs, such as groceries and
landscaping items. Petitioner would use her own earnings and the
child support payments for these expenses, and on occasion she
would also charge the expenses to credit cards which she was
responsible for paying. However, Mr. Elesh occasionally would
reimburse her for some of these expenses and make payments on her
credit cards. He also provided petitioner with a car, and he
routinely paid for certain household expenses such as the
mortgage, utilities, and car insurance. Petitioner did not make
any charitable contributions in either 1997 or 1998, and she was
unaware if Mr. Elesh made any such contributions. During the
years in issue, Mr. Elesh owned a residential rental unit in
Buffalo Grove, Illinois, which he rented to petitioner’s
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