Della H. Knorr and Duane J. Knorr - Page 23

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               At the times in 1996 that petitioner signed the joint income           
          tax returns for 1990 through 1995, she was well aware of                    
          intervenor’s past failures to file their returns on time and to             
          pay their income taxes.  Petitioner was also aware that additions           
          to tax and interest were owed on their joint liabilities for 1990           
          through 1995.  Petitioner testified as follows:                             
                    Q  [By petitioner’s counsel]  Did you have any                    
               discussions with him [intervenor] about paying                         
               penalties?                                                             
                    A  I knew that there were penalties to be paid.                   
               Yes.  But as far as how much and how they were going to                
               be paid, no.  * * *                                                    
          Despite her knowledge of intervenor’s habitual delinquency with             
          respect to their income tax obligations, petitioner agreed to               
          defer payment of the additions to tax and interest and request              
          that the additions to tax be abated.  Petitioner did not question           
          intervenor at or before the times that she signed the joint                 
          income tax returns for 1990 through 1995 as to how and when the             
          additions to tax and interest would be paid if their request for            
          abatement was denied.  Under these facts and circumstances,                 
          petitioner has not established that it was reasonable for her to            
          believe that intervenor would pay the additions to tax and                  
          interest at the times that she signed the joint income tax                  
          returns for 1990 through 1995.  Furthermore, petitioner has                 
          identified no ground warranting an abatement nor otherwise shown            
          that it would have been reasonable for her to believe that an               






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