Janice L. Morris - Page 35

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          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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