Susan L. Abelein - Page 3

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          Petitioner’s Relationship With Daniel Abelein                               
               Petitioner and Daniel Abelein (Mr. Abelein) married in 1971.           
          As of the date of trial, they were still married and living                 
          together.                                                                   
               Petitioner generally had no desire to understand and no                
          interest in business matters and did not attempt to understand              
          business documents or read fine print.  Petitioner was, however,            
          responsible for paying the household bills, and, during the years           
          at issue, she did so from her joint account with Mr. Abelein.               
          According to petitioner, although Mr. Abelein made all of the               
          family’s financial decisions,3 petitioner and Mr. Abelein decided           
          on and saved for large purchases together.                                  
               Petitioner sometimes disagreed with Mr. Abelein’s decisions            
          but was never threatened by Mr. Abelein into making investments,            
          signing their tax returns, or signing checks.  Mr. Abelein never            
          deceived petitioner about their finances or hid mail from her.              
          Mr. Abelein answered petitioner honestly if she asked him about             
          their finances.  Mr. Abelein never abused petitioner.                       
               During the years at issue, petitioner and Mr. Abelein lived            
          in the same house that they built in 1978, drove used cars, took            


               3Mr. Abelein graduated from high school and completed 2                
          years of college and an apprenticeship as an electrician.  Mr.              
          Abelein worked as an electrician and recently started his own               
          general contracting company.  As of 1986, Mr. Abelein had no                
          formal education in finance or tax and no experience in cattle              
          ranching or selling cattle.                                                 





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