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notice that it is probable that income is being omitted from a
joint return. Estate of Jackson v. Commissioner, 72 T.C. 356,
361 (1979).
We agree with respondent that the record contains ample
instances of unusual or lavish expenditures that should have
placed petitioner on notice that she and Mr. Goings were spending
more money than they were reporting on their joint returns. In
1985, the couple purchased two pieces of real estate for a total
purchase price of $190,000. They paid $47,500 in cash and
financed the remainder with a note requiring quarterly
installment payments of approximately $8,000. Similarly, in 1986
the couple established their Merrill Lynch investment account
with $150,000. In 1987, petitioner and Mr. Goings made another
real estate purchase, paying the entire $315,000 purchase price
in cash. In 1989, the couple paid delinquent taxes in the amount
of $297,345. Petitioner and Mr. Goings also purchased real
estate in 1990 for $95,000 in cash.
Petitioner's argument with respect to this factor is cursory
and lacks meaningful substance. At trial, when questioned about
the above-referenced real estate purchases and the creation of
the investment account, petitioner acknowledged her signature on
related documents but emphatically denied knowing anything about
the substance of the underlying transactions. Specifically,
petitioner claims that she routinely signed documents without
reading them and that the documents relating to the above-
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