Lloyd E. Dawson, Jr. - Page 19

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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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