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evidence to suggest that her financial arrangements with Louis,
whereby she received $160 per week for household expenses,
changed as a result of the IRA distribution.
Louis’s will bequeathed his Crossland Savings Bank IRA to
petitioner. That was Louis’s only account at Crossland Savings
Bank, and it was the source of the IRA distribution, which
occurred after the bank became Republic National Bank. The
record indicates that, by 1997, that account had been closed and
that Louis had opened another account at Republic National Bank
(the Republic account) with a different account number. As of
February 2, 1997, the Republic account consisted of a $91,213
renewable CD, and the account was referred to in petitioner’s
innocent spouse questionnaire as containing $90,000. The
February 2, 1997, CD was a 6-month CD and was a renewal of a
prior CD. The existence of the Republic account CDs at least
suggests that, after Louis withdrew the money from his IRA
(which, as depleted by the withdrawal, he had bequeathed to
petitioner), he deposited it in a new account with the same bank,
which he opened after the execution of his will, and which,
therefore, became part of his residuary estate bequeathed to his
grandchildren.
In short, there is no direct evidence of what Louis did with
the funds comprising the IRA distribution; nevertheless, we
surmise that he deposited them in a bank account that, pursuant
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