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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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