Maureen Monsour - Page 3

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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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