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account and the Ameritrust account were frequently dishonored due
to insufficient funds. This would have caused a reasonable
person to believe that Raymond's activities were losing money.
It is unlikely that an examination of the statements would have
alerted Barbara that any income was omitted.
Although we recognize that there may have been a disparity
between the family's total expenditures and their reported income
for the years 1991 and 1992, this does not necessarily indicate
that Barbara should have known of the omitted income. The record
clearly shows that the omitted funds were used primarily to
purchase Raymond's memorabilia. The relatively small amount used
to help support the family was spent primarily for groceries,
house payments, bills, and other minor living expenses.
Moreover, petitioners borrowed against their credit cards to pay
the expenses. These expenditures were in the nature of ordinary
support and would not normally give a spouse reason to know of
omitted income. See Mysse v. Commissioner, 57 T.C. 680, 698-699
(1972). There is no evidence of any lavish or extraordinary
expenditures which would have put Barbara on notice of unreported
income. Cf. Estate of Jackson v. Commissioner, 72 T.C. 356, 361
(1979); Mysse v. Commissioner, supra.
We conclude, from our examination of the evidence presented,
that there was no reason for Barbara to have known that there was
income from Raymond's sports memorabilia activity that was not
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