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of $14,340,4 which amount was assessed by respondent on February
8, 1999. At some point in 1998 or 1999, Mr. Barrera explained to
petitioner that the tax problems with the IRS stemmed from
expenses of his mortgage brokerage business that the IRS
reclassified as personal expenses and disallowed as business
expense deductions.
By late 1999 and into 2000, petitioner saw that Mr. Barrera
was working “less and less” at his successor home improvement
loan business, that cash was not coming in from Mr. Barrera’s
business as it had been earlier in their marriage, and that Mr.
Barrera did not have the same type of income anymore. Petitioner
felt that, although Mr. Barrera continued to act like “everything
was fine”, their financial situation was changing.
In late 1999, petitioner and Mr. Barrera put their Pine Bay
Estates house on the market. Petitioner did not want to sell the
Pine Bay Estates house and was not happy that it had to be sold.
When the Pine Bay Estates house had to be sold, petitioner knew
there were financial problems facing her family.
Around this same time, Mr. Barrera approached petitioner
about withdrawing money from her IRA, and she initially refused
Mr. Barrera’s request. By the time she and Mr. Barrera were
trying to sell their Pine Bay Estates house, however, petitioner
4 No deficiency was determined by respondent with respect
to petitioner and Mr. Barrera’s joint return for taxable year
1996.
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