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Witter account statements, he would show her statements that he
had “doctored up” in order to hide his withdrawals from the Dean
Witter account. When asked about the whereabouts of these
“doctored up” statements on cross-examination, however,
Mr. Ohrman acknowledged that neither he nor petitioner had
provided them and that “they were thrown away” by him or
petitioner.
The Dean Witter account statements were not the only source
of information indicating that Mr. Ohrman had taken the early
withdrawals during 1999. Two Forms 1099-R for 1999 were also
sent to the Birdshill residence--one indicating a gross
distribution and taxable amount of $71,000 from the Dean Witter
account and the other indicating a gross distribution and taxable
amount of $8,000 from the Dean Witter account. On the Innocent
Spouse Questionnaire, petitioner stated that the two Forms 1099-R
were sent to Mr. Ohrman’s work address. This statement is
inconsistent with the address clearly shown on both Forms 1099-R.
Petitioner is a fairly well-educated individual who had
gained experience with financial matters as a result of her
10 years of employment as a lending officer with two large banks.
Petitioner took complete control of her family’s finances in 1999
as a result of Mr. Ohrman’s gambling addiction, was aware of the
existence and magnitude of the Dean Witter account, and prepared
the joint 1999 return by herself. A reasonable person in
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