- 14 -
into the ultimate tax liability shown on the joint return. Price
v. Commissioner, supra; Levin v. Commissioner, T.C. Memo. 1987-
67.
With the exception of 1992 and 1993, it was Mr. Pierce's
practice to have petitioner sign blank returns, complete them,
and then mail them on April 15. Petitioner testified that she
signed blank tax returns in early April for almost every tax year
from when they were married through 1994. She claims she never
asked or questioned him about potential refunds or amounts they
owed. Based on petitioner's testimony concerning the tax return
at issue, we find that petitioner essentially turned a "blind
eye" toward the filing of the 1994 Federal income tax return and
the failure to pay the taxes shown thereon.
A taxpayer who signs a return without reviewing it, or who
signs a blank return, is charged with constructive knowledge of
the tax due shown on that return. Castle v. Commissioner, T.C.
Memo. 2002-142. Thus, despite the fact that petitioner signed a
blank return, she should have known of the liabilities shown thereon.
Petitioner also knew that Mr. Pierce had trouble managing
the finances. Petitioner testified:
Up to and before when I left, I mean, he handled all
the finances. I tried to take over the bills one time
because I didn't like the way he took care of them
because he would always pay everything like a month
late, and we made enough money together then that we
could pay the bills. It was almost like the, you know,
the last thing. If he has money left over, then he'll
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