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items to him because petitioner did not know, or have any reason
to know, that the gains were not reported on the 1987 and 1988
tax returns. Respondent contends that the capital gain income is
allocable evenly between petitioner and Mr. Rowe because the
properties were jointly titled, and petitioner would have been
required to report half of the proceeds from the sales had she
filed separate returns.
Petitioner claims that she was often required to sign
documents by Mr. Rowe under conditions where she was not allowed
to question the contents of the documents. Petitioner maintains
that Mr. Rowe did not tell her that she was listed as an owner of
assets on any of the documents she signed. Petitioner
acknowledges on brief that she and Mr. Rowe purchased properties;
however, she claims that she was unaware of the disposition of
many of the properties. Petitioner has not specifically asserted
that she unknowingly signed documents related to the Anorada
property or that she was unaware that her name was listed as a
joint owner of the property.
Lots 22 and 27 and the Anorada property were titled jointly
in the names of petitioner and Mr. Rowe. Petitioner testified
that she was aware that she was listed as joint owner of Lots 22
and 27, and she remembered the approximate purchase price of the
property. Petitioner’s testimony also reflected that she was
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