Ruth E. Neal - Page 6

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          claimed tax shelter deductions that had been disallowed by                    
          respondent, and petitioner believed Alimam’s explanation as to                
          the reason for their financial difficulties and for the                       
          bankruptcy petition that was filed.                                           
               During the hearings relating to the above bankruptcy,                    
          petitioner first learned that Alimam had purchased in his own                 
          name, among other assets, a boat, a villa in Colorado, six or                 
          seven cars, and expensive fine art.  Alimam had not informed                  
          petitioner of any of these purchases.  This first bankruptcy case             
          was closed on June 11, 1991.  The record is unclear as to the                 
          resolution of this bankruptcy case.                                           
               A number of times during the years at issue, due to Alimam’s             
          failure to pay household utility bills, the family’s utilities                
          were shut off, and on one occasion, in order to keep the                      
          utilities on, petitioner pawned a Rolex watch Alimam had given                
          her.                                                                          
               On June 16, 1995, Alimam again filed for bankruptcy, and                 
          again petitioner signed this bankruptcy petition.  This time,                 
          Alimam inaccurately told petitioner that this second bankruptcy               
          was caused by another audit by respondent in which respondent                 
          disallowed expenses claimed on their joint Federal income tax                 
          returns filed in the early 1990s relating to Alimam’s medical                 
          practice.                                                                     








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