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income of $439 in 1990 and $1,552 in 1992.
At the end of the audit, the IRS agent presented the Haltoms
with a completed Form 4549-CG that described in detail the
calculations performed to arrive at the deficiency amounts. By
signing the form, the Haltoms agreed that their total deficiency
from 1990 to 1993 was over $145,000. The Commissioner also added
fraud penalties against Jerry that totaled over $100,000.
Interest (computed only through the end of March 1997) brought
the total liability to over $370,000.
Throughout their marriage, and including the years for which
she is seeking relief from this very large liability, Linda
shared a joint checking account with her husband into which they
deposited their paychecks. Both spouses had signature authority
over the account, but Linda managed it, made most of the
additional deposits to it, and wrote most of the checks on it
that went to pay household bills.
Jerry, however, kept five other accounts at five different
banks, including one in the Caribbean isle of Antigua. He alone
had signature authority on these accounts. While Linda knew that
Jerry had an account of his own for business, she was not aware
that there was more than one account or of the balances in any of
them, since Jerry took care to receive the statements at his
office. He deposited all of his embezzlement income and whatever
prize money and bonuses he received into these five accounts, and
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