Estate of Raymond E. Jones, Deceased, Dorothy J. Jones, Independent Executrix, and Dorothy J. Jones - Page 22

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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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