Glenyce R. Peterson - Page 15

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          attributable to assets acquired for the beef farm and $65,219 is            
          attributable to out-of-pocket Schedule F expenses.  Despite                 
          whether petitioner was aware of the tax withholdings, or even the           
          depreciation deductions claimed on the return, she was fully                
          aware of the out-of-pocket expenditures.  Not only did she write            
          checks in order to pay many of the farm expenses, petitioner's              
          former husband did not conceal the assets acquired for the                  
          couple's farm; i.e. the vehicles, farm equipment, livestock, etc.           
          In fact, the nature of such assets make them noticeable, so                 
          petitioner was undoubtedly aware of there existence.  In any                
          event, a summary review of the return indicates that, even                  
          without regard to living expenses, the expenditures and tax                 
          withholdings totaled at least $101,325 more than the $90,181                
          reported as gross income for taxable year 1990.                             
               We conclude that petitioner had sufficient involvement in              
          her family's financial affairs to put a reasonable person in her            
          position on notice that the income reported in her 1990 return              
          was erroneous or that further inquiry was warranted.                        
                                  Taxable Year 1991                                   
               Just as she did for taxable year 1990, petitioner managed              
          her family's checkbooks for taxable year 1991.  On their 1991               
          return, petitioner and her former husband reported $45,000 of the           
          $186,000 that Mr. Peterson had embezzled during the taxable year.           
          Petitioner maintains that at the time she signed the return on              
          August 15, 1992, she believed that all funds embezzled by Mr.               




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