Carl Dimichele and Eileen Dimichele - Page 27

             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                  

                  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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