- 14 - into the ultimate tax liability shown on the joint return. Price v. Commissioner, supra; Levin v. Commissioner, T.C. Memo. 1987- 67. With the exception of 1992 and 1993, it was Mr. Pierce's practice to have petitioner sign blank returns, complete them, and then mail them on April 15. Petitioner testified that she signed blank tax returns in early April for almost every tax year from when they were married through 1994. She claims she never asked or questioned him about potential refunds or amounts they owed. Based on petitioner's testimony concerning the tax return at issue, we find that petitioner essentially turned a "blind eye" toward the filing of the 1994 Federal income tax return and the failure to pay the taxes shown thereon. A taxpayer who signs a return without reviewing it, or who signs a blank return, is charged with constructive knowledge of the tax due shown on that return. Castle v. Commissioner, T.C. Memo. 2002-142. Thus, despite the fact that petitioner signed a blank return, she should have known of the liabilities shown thereon. Petitioner also knew that Mr. Pierce had trouble managing the finances. Petitioner testified: Up to and before when I left, I mean, he handled all the finances. I tried to take over the bills one time because I didn't like the way he took care of them because he would always pay everything like a month late, and we made enough money together then that we could pay the bills. It was almost like the, you know, the last thing. If he has money left over, then he'llPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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