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filed petitioner and Mr. Pierce were separated. Petitioner and
Mr. Pierce were divorced on July 15, 1998.
For most of their marriage, petitioner had no knowledge of
any of their financial affairs. Petitioner did not know how much
money they had in any of their joint accounts. Except for a
brief period, Mr. Pierce managed essentially all of the family
finances until their separation, including paying bills and
making spending decisions. Mr. Pierce would tell petitioner how
much she could spend before she would go shopping for food,
clothing for the children, and most other items.
Petitioner knew that if properly managed, their combined
income was sufficient to cover their monthly expenses. She was
aware, however, that Mr. Pierce was a poor manager of money. She
was aware that Mr. Pierce would pay their bills late every month
with whatever money remained in their account. As a result,
petitioner took control of the family finances for a period of 4
to 6 months in the early 1990s. When Mr. Pierce became short on
spending money, he decided to reacquire control of the family
finances.
Mr. Pierce was generally responsible for filing their
Federal income tax returns. In most years, petitioner would sign
a blank return, and Mr. Pierce would take care of completing and
filing the return. Petitioner and Mr. Pierce filed joint Federal
income tax returns for 1973 through 1991. For the 1989, 1990,
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