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at or about the times that they filed these returns with the IRS.
At the times that petitioner signed these returns, she was aware
that each return showed a substantial tax liability and that the
total tax liabilities reported on these returns exceeded
$500,000.
After petitioner and intervenor filed their joint income tax
returns for 1990 through 1995, the IRS determined additions to
tax under sections 6651(a)(1), (2), and 6654 and interest with
respect to the tax liabilities reported on these returns. The
additions to tax were determined in the following amounts:
Year Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654
1990 $18,189 $17,904 $5,261
1991 8,017 8,907 2,049
1992 11,153 10,906 2,132
1993 18,959 13,060 –-
1994 45,022 19,009 5,306
1995 –- 2,464 4,451
Petitioner and intervenor were aware that they would be liable
for additions to tax and interest at the times that they signed
the joint income tax returns for 1990 through 1995. Prior to
signing these returns, however, petitioner and intervenor decided
that they would request that the IRS abate any additions to tax.
Accordingly, they did not pay any amounts in excess of the income
tax liabilities reported on the joint income tax returns for 1990
through 1995 at the times that they filed these returns.
Petitioner did not question intervenor at or before the times
that she signed these returns as to how and when the additions to
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