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claims and Social Security claims for disability. In 1992,
petitioner was admitted to practice law in Florida, although she
limited her law practice almost exclusively to Pennsylvania.
On July 3, 1983, petitioner, who was approximately 29 years
old, married William J. Monsour (Mr. Monsour), who was approxi-
mately 55 years old. At that time, Mr. Monsour was a successful
physician specializing in internal medicine at Monsour Medical
Center as well as a successful investor who, either alone or with
other persons excluding petitioner, had invested in various
assets. (We shall refer to the assets in which Mr. Monsour,
either alone or with others excluding petitioner, had invested as
Mr. Monsour’s assets or Mr. Monsour’s investments.)
Throughout the taxable years at issue, at least certain
household bills relating to the residence of petitioner and Mr.
Monsour were sent to Mr. Monsour’s office. Mr. Monsour took any
such bills to that residence, where petitioner reviewed them,
prepared checks to pay them, asked Mr. Monsour to sign those
checks, and mailed those signed checks to the payees. At all
relevant times, Mr. Monsour also signed checks with respect to
Mr. Monsour’s investments as well as checks with respect to the
joint investments of petitioner and Mr. Monsour. Petitioner
reviewed those signed checks and mailed them to the payees.
Before their marriage, petitioner and Mr. Monsour entered
into a prenuptial agreement (prenuptial agreement), which listed
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