- 19 - 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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