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actions being taken by their agents. We categorically reject any
such view. See Shopsin v. Commissioner, T.C. Memo. 1984-151,
wherein we stated:
Had petitioners attempted to ascertain the precise
status of their case at any particular point in time,
we believe petitioners had the wherewithal to do so.
Petitioners cannot avoid their responsibility on the
basis of their failure to press the matter.
See also Kraasch v. Commissioner, 70 T.C. at 627-628, wherein we
stated: “That * * * [the taxpayers] might not have understood the
contents or chose at times not to read their mail before sending
it to * * * [their accountant] in no way absolves them of
responsibility or knowledge in this matter.”
Petitioner also argues that Jaffe made it difficult for
James and John to appreciate what they were signing because he
typically presented them with a stack of documents, pointed to
where they were expected to sign, and stood over them while they
signed each document. However, any suggestion of undue influence
is belied by the following colloquy between the Court and James:
THE COURT: * * * Now, you said that Steve Jaffe
typically would present you with documents to sign and
basically say, Sign here.
JAMES GIBBS: That’s correct.
THE COURT: If you had expressed an interest in a
document, would he have precluded you from examining
it?
JAMES GIBBS: I don’t think so.
THE COURT: Did you feel free to examine the
document should you have so chosen to do so?
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