Lisa Marie Pierce - Page 16

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               pay the bills from whenever it was.  So I took over the                
               bills for a few months, but then he got mad because he                 
               never had enough money when he needed it.  So he took                  
               care of all the finances.                                              
          From the early 1990s, when petitioner took care of their                    
          finances, she knew that money was tight and there might not be              
          enough money to pay a large tax liability.  Petitioner should               
          have made further inquiry to determine the amount of taxes they             
          owed and whether the full liability would be paid.                          
               In addition to petitioner's knowledge of the financial                 
          difficulties faced by the family, petitioner knew of other facts            
          that should have forced further inquiry into her family's                   
          financial situation.  Petitioner had learned through common                 
          acquaintances at DOD that Mr. Pierce had quit his job in February           
          1995.  A reasonable person would, at minimum, question their                
          spouse (or ex-spouse) whether enough money remained to pay any              
          tax liability reported on their joint return.  Secondly,                    
          petitioner testified that the 1994 return was signed after she              
          and Mr. Pierce were separated.  It also seems reasonable to this            
          Court that their separation should maintain, if not heighten, her           
          duty to examine any jointly filed returns.                                  
               She also argues that because she was unaware of Mr. Pierce's           
          noncompliance with Federal tax law, before, during, and after the           
          year at issue, she had no reason to doubt that the liability                
          would be paid.  Petitioner's lack of awareness, however, does not           
          convince this Court that she did not retain an affirmative duty             





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