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different cases. Bliss v. Commissioner, 59 F.3d 374, 378 (2d
Cir. 1995), affg. T.C. Memo. 1993-390.
In the instant case, petitioner ran her own businesses,
having started them prior to the year in question. She expanded
them successfully during, and after, 1981. She handled the
buying and selling of the inventory, purchased a building out of
which the businesses were operated, and paid the mortgage. She
operated her businesses independently of Mr. Jones in spite of
her lack of formal education.
Because Mr. Jones traveled extensively and for long periods
of time, petitioner managed the family and household finances.
Petitioner also managed the Joneses’ monthly bills and large
expenditures, freely transferring funds between accounts to do
so. The evidence shows that petitioner managed most of the
family money, except for Mr. Jones’ expense account. Petitioner
demonstrated by her testimony that she kept track of Mr. Jones’
earnings and where they went. Petitioner knew about many of Mr.
Jones’ investments and asked about others.
Petitioner testified that she saw at least part of the 1981
return that she signed and that she also saw the amount of the
refund claimed. She also testified that the amount of the refund
claimed on the 1981 return was very large compared to the
overpayment claimed on the 1979 return and the tax shown as due
on the 1980 return. She signed the 1981 joint return just below
the place on the return which reflected the unusual overpayment
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