- 22 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011