Rhonda K. Juell, a.k.a. Rhonda K. Juell-Podlak, Petitioner, and Glenn M. Evans - Page 3




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               During the marriage, Glenn maintained two separate checking            
          accounts and one separate savings account.  Petitioner never had            
          access to Glenn’s separate bank accounts.  Petitioner never                 
          opened and never reviewed Glenn’s bank statements.                          
               Petitioner has never received any training or instruction in           
          business or taxes.  Over the years, petitioner has simply                   
          deposited what remained, after expenses, of her approximate                 
          $18,000 yearly salary into a checking account jointly maintained            
          by Glenn and petitioner.                                                    
               During the years in issue, Glenn was a college graduate                
          employed as a high school principal and earned approximately                
          $42,000 annually.                                                           
               During Glenn and petitioner’s marriage, Glenn handled all              
          significant financial matters, leaving some routine bills and               
          expenses to be paid by petitioner, which petitioner paid out of             
          the joint checking account.  Glenn made all mortgage and life               
          insurance payments and the payments relating to his separate                
          investments out of his separate checking accounts.                          
               In early 1990, through staff members at the school where               
          Glenn was a principal, Glenn learned of an investment opportunity           
          promoted by Walter J. Hoyt III that involved investing in cattle            
          breeding partnerships (the Hoyt partnerships).1                             


               1For a detailed description of the Hoyt partnerships see               
          Bulger v. Commissioner, T.C. Memo. 2005-147.                                





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