- 25 -25
Mrs. Zaban testified that she never reviewed any of the tax
returns, liquor license applications, or loan applications she
signed. Her testimony that she was unaware of any of the contents
in these documents lacks credibility. In any case, the fact that
Mrs. Zaban failed to review any tax returns she signed, or to sign
blank tax returns that were completed at a later time, does not
permit Mrs. Zaban to plead ignorance and does not absolve her of
liability for her husband's omissions. See Hayman v. Commissioner,
992 F.2d 1256, 1262 (2d Cir. 1993), affg. T.C. Memo. 1992-228;
Edmondson v. Commissioner, T.C. Memo. 1996-393; Cohen v.
Commissioner, T.C. Memo. 1987-537. Had Mrs. Zaban reviewed the
1984 and 1985 joint returns, she would have discovered that nearly
two-thirds of the reported gross income before adjustments resulted
from gambling; and had she reviewed the 1986, 1987, and 1988 joint
returns, she would have found that no such gambling income was
reported in those years. See Zimmerman v. Commissioner, T.C. Memo.
1996-223. Further, she would have discovered that the reported
income for 1986 and 1987 was inconsistent with the figures reported
on the loan applications submitted to Midstate, the savings and
loan institution with which she personally negotiated and discussed
the loan requirements and terms for the construction of the
Lutherville, Maryland, home. See Silverman v. Commissioner, T.C.
Memo. 1994-153.
Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 NextLast modified: May 25, 2011