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and sold limited partnerships for tax advantages. As senior vice
president of RRI, petitioner worked with investors and their
banks to obtain letters of credit, which were then discounted.
After her marriage to Trupin, petitioner spent substantial
amounts of time furnishing and arranging for repair and painting
of various residences acquired by Trupin or corporations owned or
controlled by him. Petitioner knew that the decorating
expenditures were paid by Trupin’s corporations. Although
petitioner was not regularly employed in the office of RRI after
1983, she received salaries from Trupin’s corporations as
follows:
RRI 1983 $102,392.00
1984 52,532.60
Prudential American 1984 50,000.00
Realty Corp.
No income tax was withheld from petitioner’s income from RRI
or Prudential American Realty Corp. (Prudential).
During 1982 through 1986, petitioner and Trupin enjoyed a
lavish lifestyle, accumulating, through the use of the
corporations owned and controlled by Trupin, elaborate houses,
furnishings, automobiles, art, and jewelry. They made extensive
personal use of a 105-foot yacht, known as Tara T, that was owned
and controlled by a corporation. The yacht had a crew of five
during 1982 through 1986. Corporate credit cards were used to
pay personal expenses of petitioner and Trupin.
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