Glenyce R. Peterson - Page 14

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          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 is                 




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