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and 1991 tax years, petitioner and Mr. Pierce had unpaid tax
liabilities. All of their unpaid tax liabilities were paid in
full on or before March 5, 1993. Until 1996, petitioner did not
know that they had underpayments of tax for 1989, 1990, and 1991.
During each tax filing season for the 1992 and 1993 tax
years, petitioner noticed that Mr. Pierce had not brought her
that year's return to sign. Cognizant of the time of year,
petitioner asked Mr. Pierce what happened to the tax returns; as
a result of her questioning, in both years, Mr. Pierce brought
her a blank return to sign. She signed the blank returns and he
said he would file them. Mr. Pierce never filed either return.
Until 1996, petitioner was unaware that Mr. Pierce had not filed
the 1992 and 1993 returns.
Petitioner and Mr. Pierce timely filed their 1994 Federal
income tax return. Line 64 of the 1994 Form 1040, U.S.
Individual Income Tax Return, showed that petitioner and Mr.
Pierce owed $6,401.98. At the time the return was filed, they
did not enclose a payment. Petitioner did not know, until 1996,
that they had an unpaid tax liability for 1994.
On February 15, 1996, a Notice of Levy on Wages, Salary, and
Other Income was sent to both petitioner and Mr. Pierce at their
marital address. Petitioner had moved from this address when she
separated from Mr. Pierce in November 1994. Mr. Pierce continued
to reside there until January 1996. On April 1, 1996,
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