- 35 -
generated from those operations during those years.
As for the checks drawn during 1988 from the Trust 768
account in the amount of $3,969.91 and from the MCIC account in
the amount of $4,550 that were received by or expended on behalf
of petitioner, under the circumstances presented here, we do not
think that petitioner should have inquired further about the
source of those funds, especially since Mr. Morris controlled the
affairs of those entities. Indeed, we believe that any attempt
by petitioner to inquire further about the source of any of the
excess funds in question (or about any funds of Accu-Data, Trust
768, Meadows, and MCIC which she received or from which she
benefited during the years at issue) or about the possibility of
a substantial understatement in any of the joint returns in
question would have been resisted by Mr. Morris and would have
been fruitless.
Respondent contends that petitioner's level of education was
such that she should have investigated further about the excess
funds from the bank accounts of Accu-Data, Trust 768, Meadows,
and MCIC during 1987 and 1988 totaling $11,775 and $26,080.63,
respectively. We disagree. Not only did Mr. Morris control the
affairs of those entities, take affirmative steps to deceive and
otherwise prevent petitioner's discovery of the embezzled funds,
and refuse to be open with her about his financial affairs, he
also prepared the joint returns in question, as well as at least
some of the returns covering the years at issue that were filed
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