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of tax. The deductions were not hidden in the recesses of the
return but were clearly set forth on Schedule E. The sum of the
losses from Schedule E, totaling $106,755, was set forth on line
17 on the front page of the return. Clearly, under such
circumstances, petitioner should have been on notice of the
substantial and unusual losses. Petitioner, however, testified
that she did not examine the return in any detail and that she
signed the return even though she had questions about it. As
stated above, petitioner is not entitled to turn “a blind eye” to
such facts. Park v. Commissioner, 25 F.3d at 1299.
As to the notion that “an expert” prepared the Joneses’
return, thereby relieving petitioner from pursuing questions she
might otherwise have raised, it was petitioner who found Mr.
Singleton and was the first to make use of his services. She
introduced him to Mr. Jones who then hired him to do their joint
return for 1981. She had some responsibilities in helping the
accountant and Mr. Jones prepare the return; i.e. gathering the
information on their charitable contributions and her businesses.
Under the circumstances, we do not think that she should now be
allowed to claim that she was denied access to the return
preparer.
Based on the record in the instant case, the image we have
of petitioner is that of an intelligent, inquiring, and diligent
businesswoman. Even though she lacked formal education, her
experience in the business world was certainly a good substitute.
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