Glenyce R. Peterson - Page 17

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          return.  Because petitioner did not conduct such an inquiry,                
          respondent contends that she failed to discharge her duty to                
          inquire.  Consequently, respondent maintains that, at the time              
          she signed her 1991 return, petitioner knew or had reason to know           
          that such return contained a substantial understatement.                    
               We find respondent's argument in this regard unpersuasive.             
          We reject her assertion that petitioner was obligated wholly to             
          discard the trust and confidence she had in Mr. Peterson simply             
          because he had engaged in prior illegal activity.  However,                 
          petitioner bears the burden of proof on this issue, and she has             
          fallen short in carrying that burden.  Rule 142(a); Welch v.                
          Helvering, 290 U.S. 111 (1933); see Purcell v. Commissioner, 826            
          F.2d at 473; Sonnenborn v. Commissioner, 57 T.C. at 381-383                 
          (1971).  Petitioner's argument with respect to taxable year 1991            
          is bootstrapped to her argument with respect to taxable year                
          1990.  She maintains that she lacked reason to know of the                  
          understatement for 1991 because her husband's embezzlement                  
          activities took place at his law office and not at the couple's             
          residence.  For reasons explained earlier in this opinion, we               
          find this argument unpersuasive.  Petitioner has provided little            
          convincing evidence in this case, and her arguments are cursory             
          and attenuated.   Moreover, although petitioner testified that              
          she questioned the staff at Mr. Peterson's office about the                 
          embezzlement, she failed to corroborate that testimony.  Because            
          petitioner's testimony in this regard is self-serving and                   




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