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shown petitioner that the amount of income Ms. Dawson was
receiving from her employers was larger than the amount he
claimed to have believed that it was during 1988. A taxpayer
claiming innocent spouse relief cannot simply turn a blind eye to
facts within his or her reach that would have put a reasonably
prudent taxpayer on notice that further inquiry needed to be
made. Sanders v. United States, supra at 169; Bokum v.
Commissioner, 94 T.C. at 148; McCoy v. Commissioner, 57 T.C. 732,
734 (1972).
Moreover, in March 1989, petitioner opened a joint checking
account at First National Bank of Mid County, into which he
deposited certain of Ms. Dawson’s payroll checks, checks that
petitioner concedes represented some of the funds embezzled from
PAHHS and BHHS. Petitioner reviewed and reconciled the
statements for the account. As stated above, petitioner admitted
that he assumed responsibility for writing checks to pay his
family’s bills at that time, prior to the time the 1988 return
was filed in April 1989. Petitioner should have become aware no
later than March or April 1989 of the true level of his family’s
income and expenditures. Moreover, petitioner assisted Ms.
Dawson in preparing their 1988 joint income tax return.
In addition to his involvement in his family’s financial
affairs, we consider it significant that petitioner was involved
in the business of Ms. Dawson’s employers, PAHHS and BHHS.
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