- 17 - Campbell never discussed the details of his trading activities with petitioner. Further, the totality of the circumstances indicates that Mr. Campbell was evasive about the family finances. Although the financial statements from petitioner’s Refco account were mailed directly to her home address, Mr. Campbell had complete control over the cashflow into and out of her account. He treated the funds in petitioner’s Refco account as available for use in offsetting losses in his other trading activities. Mr. Campbell did not consult her when he withdrew $2.6 million from her Refco account to invest in the London straddle. In addition, Mr. Campbell failed to inform petitioner that their accountant warned him that the loss resulting from the London straddle would be disallowed. We find that Mr. Campbell’s act of depriving petitioner of the benefit of the money earned in her account and using it to finance a tax-motivated transaction without informing her amounts to evasive conduct. We next address the issue of whether there is evidence of any substantial unexplained improvement in the family’s standard of living. Petitioner did not benefit from the underreported income. The money invested into the London straddle from petitioner’s account was never returned to her. There is evidence that the Campbells’ lifestyle began to deteriorate in 1983, and it continued to do so over the next decade. Because ofPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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