- 10 - Mr. Kelly entertained business associates at restaurants, Mrs. Kelly sometimes accompanied him. On these occasions she and other women present would carry on their own conversations. At Mr. Kelly's request, Mrs. Kelly sometimes assisted him in maintaining records of the entertainment expenses for purposes of reimbursement. Mrs. Kelly took no part in the preparation of the joint tax returns for the years at issue. Each of the returns was prepared and signed by the accountant, and then delivered to petitioners for their review. Mrs. Kelly signed the returns without review or inquiry. Mrs. Kelly made no attempt to inform herself of their contents because she trusted Mr. Kelly completely, not because he in any way hindered or discouraged her from doing so. She endorsed the refund checks they received, but neither asked nor cared what Mr. Kelly would do with the money. In 1989 Mrs. Kelly learned that Mr. Kelly was in a controversy with the Internal Revenue Service. She signed a power of attorney to authorize lawyers to represent them in administrative proceedings. Mr. Kelly did not show her any correspondence with the lawyers regarding the nature of the controversy, and she remained ignorant of the details until after the years at issue. Petitioners experienced no marked changes in their lifestyle during or after the years at issue. Mrs. Kelly received noPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011