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ments and other financial information relating to this account
were received by Thomas Dillon at Dillon Securities. Petitioner
admits that she did not review the 1982 Federal income tax return
but maintains that, even if she had, because she did not know of
the existence of the Murphy Favre account, she would not have
noticed that income from this account was not reported on the
return.
Respondent, on the other hand, points out that the account
at Murphy Favre was listed in the 1981 Federal income tax return.
Petitioner testified that Thomas Dillon always had enough money
at Dillon Securities to pay her credit card bills and provide her
with money to spend. Although petitioner was generally aware
that their tax bill for 1981 was high (the Dillons paid nearly
$250,000 in June 1982) she also believed that Thomas Dillon had
enough money in various accounts at Dillon Securities to pay
their tax liability. Respondent claims that this is sufficient
evidence of actual knowledge of the account on the part of
petitioner. Further, respondent notes that Thomas Dillon never
deceived petitioner or refused to discuss the family finances
with her.
Despite the fact that the Murphy Favre account was listed in
the Dillons' 1981 Federal income tax return, we find that peti-
tioner did not have actual knowledge concerning the existence of
the account. Petitioner has credibly testified that she did not
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