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Occasionally, she wrote out West Pine checks under Mr. Quinn's
direction, for his signature. What knowledge she had of West
Pine's activities was limited to information gathered from this
ministerial duty. As underscored by Mrs. Quinn's strong
emotional reaction to recalling the events related to the Credit
Alliance suit, even after the passing of 12 years, she had-no
awareness of any of Mr. Quinn's business activities that would
give rise to personal liability prior to her discovery of that
matter in June of 1982, after the years involved in this case.
Up until that time, Mrs. Quinn had trusted Mr. Quinn and had no
reason to question his actions. See Pietromonaco v.
Commissioner, 3 F.3d 1342 (9th Cir. 1993), revg. T.C. Memo.
1991361 and T.C. Memo. 1991-472 (Supplemental Opinion).
Moreover, even if she had learned of the Credit Alliance matter
before the filing of their 1981 individual tax return, that
would not have alerted her to the possibility that Mr. Quinn had
received unreported income from West Pine. If anything, that
lawsuit, plus Mr. Quinn's apparent failure to receive his
regular paychecks from West Pine, would have suggested that West
Pine had no money, not that Mr. Quinn was diverting corporate
receipts.
Mrs. Quinn has maintained a moderate lifestyle, with no
lavish expenditures. For most of her married life, she has lived
in the house purchased and occupied by her parents. She and her
husband have worked their entire adult lives, regularly setting
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