petitioner knew or had reason to know of the substantial understatement of tax in 1986 attributable to the unreported gain from the sale of the 506, 508, and 510 Fitzwater Street properties. During petitioner's testimony at trial, she made no specific reference to the 506, 508, and 510 Fitzwater Street properties. Rather, she testified that she had no involvement in the purchase of any of the properties acquired by the couple. Her testimony is as follows: Q All right, You heard Carl describe the various properties that were purchased beginning in 1981, going forward. Tell His Honor your involvement in purchasing or any aspect of those properties. What was your involvement in those? THE WITNESS: Well, I really had no involvement, Your Honor. As far as things went, as purchasing of all the property, I left that all up to my husband because he was the one that had the talent to do all those things and I just didn't understand if he bought something or maybe he was selling something or he fixed a building or he would resell it, and I just never knew what was going on at that time. Similarly, in her post-trial brief, petitioner does not specifically deny that she knew of the FitzwaterPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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