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addition, he paid most of the routine expenses for Linda,
Michael, and Leslie. In 1988 and 1989, petitioners maintained
separate checking accounts.
In 1989, Linda, in an attempt to become financially
independent, sought employment. The city of Plano hired her as
director of the "Keep Plano Beautiful" program. Linda received
an annual salary of approximately $24,000 and was responsible for
organizing volunteers for litter control and recycling programs.
In October 1989, Linda filed suit for divorce. The divorce
was granted on April 30, 1990. The divorce agreement provided
that (1) Ronnie would indemnify Linda for any underpayment of
taxes attributable to their 1989 joint return and (2) Linda would
receive the marital residence, the Cadillac, certain jewelry,
personal items, and alimony of $2,500 per month. Ronnie made the
required alimony payments until early 1992. Since then, however,
he has failed to make approximately $21,000 of alimony payments.
Ronnie advised Linda that they should file a joint return
for 1989. Linda agreed, and Ronnie prepared their 1989 return
using worksheets that delineated the income and expenses of his
law practice. Linda did not see these worksheets. In October of
1990, Linda met Ronnie at his law office to sign their 1989
return. Linda did not review the return or ask Ronnie any
questions relating to the accuracy of the return before she
signed it.
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