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in order to check on Mr. Monsour’s investments in the Sarasota
area (Mr. Monsour’s Florida investments) which, as discussed
above, included Monsour Gator Groves, the Three Crowns Hotel,
Azure Tides, Inc., Georgetown Square, the Three Crowns Hotel Back
Court, the Beach Road apartment, and the Lido Beach apartment.
With respect to each such monthly trip, Mr. Monsour usually left
on a Wednesday evening and returned on the following Monday
morning. At all relevant times, including throughout the taxable
years at issue, petitioner knew about Mr. Monsour’s monthly
trips. Sometimes petitioner traveled with Mr. Monsour on those
trips, although she was not involved in checking on Mr. Monsour’s
Florida investments.
From the time of their marriage on July 3, 1983, until 1986,
petitioner and Mr. Monsour did not worry about money and did not
scrutinize their discretionary spending to any significant
extent. Starting in 1986 and continuing throughout the taxable
years at issue, Mr. Monsour began to experience certain Federal
income tax (tax) problems and certain other nontax problems
(discussed below) with at least certain of Mr. Monsour’s Florida
investments. As a result, petitioner and Mr. Monsour began to
scrutinize their discretionary spending much more than they had
in the past. At all relevant times, petitioner knew that Mr.
Monsour spent a large amount of money on Mr. Monsour’s Florida
investments and believed that that amount was extravagant. At a
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