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reason to know that the grocery/convenience store income was not
reported.
Taxpayers have an obligation to review tax returns before
signing them, and they are ordinarily charged with constructive
knowledge of the contents of the returns if they do not review
them. Hayman v. Commissioner, 992 F.2d 1256, 1262 (2d Cir. 1993),
affg. T.C. Memo. 1992-228. Taxpayers generally cannot turn a blind
eye to what is disclosed on the tax return and plead ignorance.
Edmondson v. Commissioner, T.C. Memo. 1996-393; Cohen v.
Commissioner, T.C. Memo. 1987-537.
Mrs. Taylor's knowledge of, and involvement in, the
grocery/convenience store business put her on notice of the
unreported income, even though petitioner may have suggested to her
that the business was losing money. See Alberts v. Commissioner,
T.C. Memo. 1986-483. When that income was omitted from the joint
returns, Mrs. Taylor had a duty to inquire of petitioner as to the
reporting of that income. See Zimmerman v. Commissioner, T.C.
Memo. 1996-223. Petitioner's financial and criminal problems
should have also prompted Mrs. Taylor to review the joint returns.
See Starr v. Commissioner, T.C. Memo. 1995-190, affd. without
published opinion 99 F.3d 1146 (9th Cir. 1996).
Mrs. Taylor presented no evidence supporting her innocent
spouse claim with respect to the other items of income (which
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