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income and $48.50 of omitted interest income. In Cheshire v.
Commissioner, supra, we faced a similar situation wherein the
spouse claiming relief from joint liability relied upon her
husband for the accurate preparation of their income tax return.
In that case, we stated:
Petitioner trusted and relied upon Mr. Cheshire
when it came to the preparation of their tax returns.
She is an elementary school teacher, having taken no
courses in accounting or tax return preparation. She
asked Mr. Cheshire about the potential tax
ramifications of the retirement distributions, and Mr.
Cheshire assured petitioner that he had consulted with
a certified public accountant and had been advised that
the payment of the outstanding mortgage on the family
residence and any amount rolled over into a qualified
account reduced the taxable amount of the retirement
distributions. Mrs. Cheshire had no reason to doubt
the truthfulness of Mr. Cheshire’s statement, and in
fact believed him. Under these circumstances, we do
not believe petitioner had an obligation to inquire
further. [Id. at 199.]
Petitioner has no background in accounting, tax, or other
financial matters, and she was primarily a housewife during her
marriage to Mr. Rowe. Like the spouse claiming relief in
Cheshire v. Commissioner, supra, petitioner trusted and relied
upon her husband when it came to the preparation of their 1990
tax return, and she believed him when he told her the tax return
was correct. For 1990, respondent determined that petitioners
failed to report $4,847 of interest income from various sources.
The amount of $97 related to petitioners’ NCNB account. The
parties stipulated that petitioner is entitled to relief from
joint liability under section 6015(c) for all but $48.50 of the
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