- 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 filedPage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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