Lisa Marie Pierce - Page 15

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          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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