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light of petitioner's testimony that, although she was unaware of
her husband's annual salary from Allied, she believed that such
salary was approximately $50,000. Petitioner does not attempt to
explain this disparity. That is, petitioner does not attempt to
explain how Mr. Goings could deposit the above amounts into the
joint account while supposedly earning $50,000 per year. A
taxpayer claiming innocent spouse relief cannot simply turn a
blind eye to facts within his or her reach that would have put a
reasonably prudent taxpayer on notice that further inquiry needed
to be made. Sanders v. United States, supra at 169.
Similarly, the couple's Merrill Lynch investment account was
also a joint account, and, between 1987 and 1989, a total of
$760,000 was deposited into such account. The statements for the
Merrill Lynch account were mailed to the couple's residence and
were readily available for petitioner's review. We decline to
accept petitioner's self-serving testimony that she never
examined such records because such testimony is unreasonable and
lacks credibility.
The third factor we consider is the presence of unusual or
lavish expenditures by petitioner's family. A taxpayer claiming
relief as an innocent spouse cannot close his or her eyes to
unusual or lavish expenditures that might have alerted him or her
to unreported income. Terzian v. Commissioner, 72 T.C. 1164,
1170 (1979); Mysse v. Commissioner, 57 T.C. 680, 699 (1972). The
presence of unusual or lavish expenditures may put a taxpayer on
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