Barbara Rooks - Page 9

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          “is the one who failed to properly file the tax returns in                  
          question” and that “the taxes owed are my ex-spouse’s and not               
          mine.”                                                                      
               The circumstances surrounding the filing of the tax returns            
          for 1989 through 1993 by petitioner and Mr. Rooks are unclear.              
          Prior to trial, petitioner asserted that she signed blank tax               
          returns for each of the years 1989 through 1993 prior to the time           
          when each individual return was due in the corresponding month of           
          April.  She claimed that she signed blank returns because “the              
          tax deadline was so close”.  She further maintained that the                
          returns which were filed in November 1994 were amended returns              
          meant to correct errors on the original returns.  Petitioner                
          specifically asserted that these amended returns were made on               
          Forms 1040X.  However, it is clear from the record that the                 
          returns filed in November 1994 were on Forms 1040.  Petitioner              
          stated at trial that the returns she signed in each April must              
          not have been filed, but she did not explain why the November               
          1994 returns also would have been filed on Forms 1040.  She                 
          further testified that the forms she signed in November 1994 were           
          blank, stating that “there were extenuating circumstances about”            
          the returns.  Petitioner, however, did not offer any testimony              
          specifically addressing what the circumstances were in November             
          1994 which caused her to sign blank returns, since no deadlines             
          were approaching at that time.  Finally, petitioner’s various               






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