Carla J. Zimmerman - Page 11

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          of some $26,000.  The Zimmermans' tax returns reported total                
          income of only $3,376.20 for 1988 and $808.37 for 1989.                     
               The returns as filed had very few entries and were rather              
          simple.  Had petitioner made even a cursory review of the                   
          returns, she would have been alerted to the fact that none of her           
          W-2 income was reported and that at least some income from the              
          business had been omitted.  Petitioner had a duty to inquire                
          about these omissions.  The total amount of income reported each            
          year was minuscule compared to the amount of money flowing into             
          her household account.  Thus even a glance at the tax returns               
          would have put a reasonable person on notice that something was             
          wrong.  Petitioner wrote checks for mortgage payments in 1989               
          that alone totaled $5,191.20.                                               
               We hold that petitioner knew or had reason to know of the              
          substantial understatements of tax.  Therefore, she does not                
          qualify for relief under section 6013(e), and we need not                   
          consider whether it would be inequitable to hold her liable.                
               In keeping with the foregoing,                                         
                                                  Decision will be entered            
                                             for respondent.                          












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