-6-
December 1999 search.4 Mrs. Paterson herself never used these
telephones.
Mrs. Paterson also assisted her husband in concealing assets
to help hide his bookmaking activity. Petitioners’ joint bank
accounts had only minimal activity during the years at issue.
Mrs. Paterson kept separate bank accounts and brokerage accounts,
however, solely in her own name. She made numerous deposits of
large sums totaling thousands of dollars into these accounts
during the years at issue. Many of these deposits were of cash
or checks made payable to her husband.
Mrs. Paterson also kept significant assets in her own name
rather than having assets titled in both petitioners’ names or
having assets titled only in Mr. Paterson’s name. For example,
the home in which she and Mr. Paterson have resided for the past
20 years is solely in Mrs. Paterson’s name, and she is the only
person listed on the mortgage. She also paid approximately
$34,000 cash in 1997 to buy a Cadillac for her husband to use,
paying with a check drawn on her checking account. The vehicle
purchase contract was in Mrs. Paterson's name.
4The Court finds petitioners’ testimony that Mrs. Paterson
obtained the cellular phones for a computer business they were
trying to start inconsistent with other evidence in the record.
Neither petitioner reported any income or expenses relating to
the computer business. Presumably phone costs could be expensed
if they were incurred in a trade or business. Moreover,
petitioners have not introduced any evidence corroborating their
testimony concerning the computer business.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007