Maurice D. and Elinor Taylor - Page 25

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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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