Christiana Stamoulis - Page 4

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               Starting in June 2000, and at all relevant times, petitioner           
          was employed as an investment banker with Goldman Sachs in New              
          York, New York.  Petitioner’s 2002 return shows her adjusted                
          gross income as $114,819.  According to petitioner, her income              
          for that year represented a temporary, albeit significant drop in           
          her usual annual income due to the status of the economy at the             
               Petitioner describes herself as an “impulsive buyer” whose             
          annual expenditures for clothing and shoes might be deemed by               
          some to be rather extravagant.3  Furthermore, it appears that her           
          wardrobe is constantly changing.  According to petitioner, she              
          routinely purchases designer clothing and shoes, wears the items            
          once or twice, and then donates them to an upscale thrift shop in           
          New York, New York.  Despite the fact that her 2002 income was              
          substantially less than usual, petitioner claims not to have                
          modified that routine during that year.                                     
               Petitioner’s timely filed 2002 Federal income tax return               
          includes a Schedule A, Itemized Deductions, on which a $55,764              

          2  For example, petitioner’s 2003 Federal income tax return shows           
          adjusted gross income of $192,535 and property gifts to charities           
          of $133,202.                                                                
          3  On the basis of her credit card charges, petitioner estimates            
          that she spent $53,916 on clothing and $9,253 on shoes during the           
          year in issue.                                                              

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