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husband’s retirement income, which income she asserts is a
primary reason for the underpayments. She also argues that she
was unaware of Mr. Rooks’s noncompliance with Federal tax law,
before and during the years at issue, because he had actively
deceived her during that time concerning taxes and other
financial matters. Finally, petitioner argues that she was
subjected to mental abuse by Mr. Rooks, and petitioner points to
medical problems suffered by petitioner, Mr. Rooks, and
petitioner’s father. Petitioner did not corroborate her cursory
testimony concerning these assertions: She failed to show that
she did not benefit from the retirement income, she failed to
show a pattern of deception, she failed to provide examples of
mental abuse, and she failed to show that any medical condition
somehow affected her in a manner relevant to the payment of the
income tax liabilities.
Petitioner admits that she signed the returns that were
filed in November 1994. These returns are the basis for the
joint and several liability for the 1992 and 1993 taxable years.
Petitioner signed these returns which showed balances due, along
with the returns for 1989 through 1991, months or years after
they were required to be filed. We agree with respondent that
the central issue in this case centers around the lack of payment
of the liabilities shown on these clearly delinquent returns.
Petitioner has not provided this Court with credible evidence to
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