- 14 - Commissioner, 6 T.C. 1158 (1946), affd. 162 F.2d 513 (10th Cir. 1947); see also Glimco v. Commissioner, 397 F.2d 537, 541 (7th Cir. 1968, affg. T.C. Memo. 1967-119); Frierdich v. Commissioner, 925 F.2d 180 (7th Cir. 1991). Petitioner also attempts to restrict the amount of weight we attribute to her involvement in her family's financial and business affairs by arguing that Mr. Peterson's embezzlement activities occurred at his law office and not at the couple's residence, explaining that the embezzled funds were funneled through the law practice and that she possessed minimal knowledge about such practice. This argument is without merit as it attempts to shift our focus of inquiry from her family's financial activities to Mr. Peterson's law practice. Granted, petitioner may not have known much about her former husband's law practice, but she knew how much money the family was spending and how much it was reporting as income. 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 was necessary. Sanders v. United States, 509 F.2d at 169; Bokum v. Commissioner, 94 T.C. at 148; McCoy v. Commissioner, 57 T.C. 732, 734 (1972). Even a cursory examination of petitioner's 1990 return should have placed her on notice that something was amiss. The return listed expenditures and tax withholdings totaling approximately $191,506. Of this amount, roughly $95,319 isPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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