Della H. Knorr and Duane J. Knorr - Page 9

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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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