- 46 - 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 settingPage: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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