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spouse benefiting from any other expense pay that expense.
Petitioners maintained separate financial accounts and did not
own any financial account jointly. When one of them paid a
common expense in full, or paid an expense of the other, the
other one typically wrote contemporaneously a check to the payee
for half of the expense (in the case of a common expense) or for
the full expense.
B. LeBloch
James G. LeBloch (LeBloch) received a law degree from the
University of Illinois in 1972 and a graduate law degree in
taxation from New York University in 1978. He worked for General
Motors Corp. from about 1972 through 1980, except for
approximately 9 months when he was earning his graduate law
degree. He worked as tax counsel for Monsanto Corp. from about
1980 through 1988 and as a chief financial officer for Seagate
Technology from 1988 through 1990. He worked from 1990 through
1999 as a senior attorney in respondent’s Office of Chief Counsel
in Los Angeles, California. He has worked in private practice as
a tax attorney since 2000.
C. Nature’s Touch
Michelsen formed and operated three retail gift shops known
as Nature’s Touch. From January 1 through November 23, 1997, she
operated two of the shops as a sole proprietor; she operated the
third shop as a sole proprietor from its opening on November 1,
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