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 Fitzwater
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