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The record is clear that Mrs. Taylor knew of the substantial
understatement of income from both petitioner's check-kiting scheme
and the grocery/convenience store business. Mrs. Taylor admitted
at trial that she was told by petitioner of the check-kiting scheme
in July 1988, approximately 3-1/2 years prior to the filing of the
delinquent returns. This fact prevents Mrs. Taylor from obtaining
innocent spouse relief with respect to the check-kiting income in
1988. See Krause v. Commissioner, T.C. Memo. 1991-13; Newton v.
Commissioner, T.C. Memo. 1990-606; Bents v. Commissioner, T.C.
Memo. 1990-487. Although Mrs. Taylor may not have known the tax
consequences of the check-kiting scheme, that ignorance is no basis
for relief. See Krause v. Commissioner, supra; Newton v.
Commissioner, supra; Trimmer v. Commissioner, T.C. Memo. 1983-131.
With respect to the grocery/convenience store business, Mrs.
Taylor was fully aware that this business existed during 1988,
1989, and 1990, and she even worked in the store for a short period
during 1990 and much of 1991. Although Mrs. Taylor may have
believed from her conversations with petitioner that the
grocery/convenience store was operating at a loss during the years
in issue, she knew from her participation in the business that the
grocery/convenience store was generating gross receipts. Mrs.
Taylor made deposits of cash receipts and wrote checks to creditors
while working at the store. She testified, however, that she did
not review the joint returns she signed, and thus she never had
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