Maureen Monsour - Page 7

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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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