- 15 - 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 notPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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