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attended and graduated from Tulane University; Alexis attended
and graduated from Northeastern University. Nicole and Michael
also each had the use of a car while attending college. Levy
paid for the acquisition cost, insurance, and maintenance of the
cars used by Nicole and Michael.
From 1974 through the time of the trial in this case,
petitioner did not enjoy a lavish lifestyle. During their
marriage, Levy did not give her expensive gifts or jewelry.
Petitioner did not buy lavish household furnishings or clothes.
During this time she and her family did not take trips abroad.
Most of the vacations she and her family took were visits to
family in Margate, Florida, and in New York State.
For a number of years, Levy had a serious gambling problem.
Although petitioner knew that Levy gambled on occasion, she did
not know of the extent and seriousness of his problem until
around 2001.
B. The 1979 Deficiency
On April 15, 1980, petitioner and Levy jointly filed a Form
1040, U.S. Individual Income Tax Return, for 1979 that was
prepared by an accountant employed by Levy. Petitioner signed
the return, but she had no involvement in the preparation of the
return. No discussions took place between petitioner and Levy
about the preparation of the 1979 joint return. The 1979 joint
return reflected adjusted gross income of $26,827.66, taxable
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