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of $71,312. During 1979, Mr. Crowley earned $81,925 in
commissions from the James Sinclair Trading Corporation. On June
15, 1981, petitioner and Mr. Crowley signed a joint tax return
for taxable year 1980, which was filed before the end of the
month, and reported an adjusted gross income of $8,055 and tax
due of $240. During 1980, Mr. Crowley earned $122,683 in
commissions from Sinclair Securities Company. On January 26,
1983, petitioner and Mr. Crowley signed a joint tax return for
taxable year 1981, which was filed on January 31, 1983,6 and
reported an adjusted gross income of $90,658 and tax due of
$13,980. During 1981, Mr. Crowley earned $148,141 in commissions
from Sinclair Securities Company. Petitioner signed the joint
returns for 1979, 1980, and 1981 without reviewing them.
The losses disallowed in the notices of deficiency were
claimed by petitioner and Mr. Crowley on their 1979, 1980, and
1981 joint tax returns as Mr. Crowley's share of losses incurred
by TSM Associates, Sinclair Securities Company, and APEX
Associates. During the years 1979, 1980, and 1981, Mr. Crowley
earned more than $380,000 in commissions.
Petitioner and Mr. Crowley entered into a settlement
agreement with respondent that provides that petitioner and Mr.
6
Petitioner concedes that she is liable for the addition to
tax for failure to file timely with respect to that return,
unless she is relieved from such liability as an innocent spouse.
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