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partnership using funds out of his expense account at Citizens
State Bank, in Sealy, Texas. During 1981, petitioner did not
know that Mr. Jones maintained a separate bank account for his
business and travel expenses. However, she knew that Mr. Jones'
employer, Brown & Root, paid for his travel by advancing him
funds, and that he did not deposit those funds into their
household account. Nonetheless, petitioner did not know about
the $10,000 investment in the Auburn Mining partnership when Mr.
Jones made it.
On their 1981 return, the Joneses claimed an overpayment of
$17,732.28, resulting at least in part from the deductions taken
from the Auburn Mining and Choate Square partnerships. The 1981
return, with its overpayment claim, contrasted with their 1979
and 1980 returns, which respectively reported an overpayment of
only $33 and an amount due of $1,444. A substantial portion of
the refund claimed on the 1981 return was carried over to be used
as an additional payment on the income tax liability shown on the
joint return filed by the Joneses for their 1982 taxable year.
Petitioner signed the returns filed for taxable years 1979
and 1980, as well as the return filed for the 1981 taxable year.
Although she signed the tax returns, petitioner did not see the
complete returns or inspect each of the pages given to her
because Mr. Jones always presented them for signature at
inconvenient times. Petitioner did not inspect the portions of
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