- 2 -
references are to the Internal Revenue Code, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Petitioner’s Background and Lifestyle
Petitioner attended the University of Oklahoma, where she
received an undergraduate degree in interior design and painting.
In 1971, she received a masters in art history. Petitioner
married Trupin on September 23, 1982, after executing an
antenuptial agreement. Petitioner and Trupin executed a
separation agreement on April 23, 1993. The separation agreement
provided in part:
The parties acknowledge that there are certain tax
deficiency claims pending against them with respect to
joint Federal income tax returns filed by them.
Notwithstanding anything to the contrary contained
herein, the Husband hereby assumes responsibility for
any and all potential liabilities, including, but not
limited to, penalties, interest and expenses arising
out of such claims and he hereby agrees to hold the
Wife harmless from and to indemnify the Wife against
the same.
The separation agreement contained a mutual release of any debts
or obligations between Trupin and petitioner other than those set
forth in the separation agreement. Petitioner married Brice
D’Aunay (D’Aunay) in France on June 5, 1993.
Trupin was the chairman of the board of Rothschild Reserve
International (RRI) and controlled various subsidiary and
affiliated corporations. Petitioner was an employee and/or
senior vice president of RRI from 1979 to 1984. RRI structured
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011