Rosemarie Meyer - Page 7

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          did not read or review the return, nor did she ask any questions            
          pertaining to it prior to affixing her signature.  She claimed no           
          knowledge of financial affairs and tax matters.  Mrs. Meyer                 
          acknowledged that if she had questioned her husband regarding the           
          return he would have answered her truthfully.                               
               On June 23, 1994 respondent timely mailed a statutory notice           
          of deficiency to petitioner and her husband in which a deficiency           
          was determined for 1989 in the amount of $59,718 in income tax              
          and additions to tax of $3,076 and $4,182 pursuant to sections              
          6651(a)(1) and 6654(a), respectively, and a penalty of $11,944              
          pursuant to section 6662.  Respondent derived the income tax                
          deficiency from:  (1) The omission from income of a $180,748                
          constructive dividend from AED; (2) disallowed Schedule C                   
          expenses in the amount of $19,753; (3) a reduction of $20 to                
          Schedule C income reported; and (4) an increase of $161 for                 
          omitted interest income from petitioner's personal accounts at              
          Norstar and Dollar Dry Dock banks.  Petitioner conceded the                 
          correctness of the amounts of all items in the deficiency,                  
          asserting only that she qualified for innocent spouse relief.               
          Petitioner does not argue or attempt to prove that the omitted              
          income adjustment of $161 or the adjustment in favor of the                 
          petitioner of $20 for overstated Schedule C gross receipts set              
          forth in the statutory notice of deficiency qualifies for                   
          innocent spouse relief.  Accordingly, petitioner has not met her            
          burden of proof with respect to these adjustments.  Rule 142(a).            




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