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abatement would be granted. We have consistently applied the
principle that the provisions providing relief from joint and
several liability are “designed to protect the innocent, not the
intentionally ignorant”. Dickey v. Commissioner, T.C. Memo.
1985-478; see, e.g., Morello v. Commissioner, supra; Demirjian v.
Commissioner, T.C. Memo. 2004-22; Feldman v. Commissioner, T.C.
Memo. 2003-201; Taylor v. Commissioner, T.C. Memo. 1997-513;
Barnhill v. Commissioner, T.C. Memo. 1996-97; Shannon v.
Commissioner, T.C. Memo. 1991-207; Berry v. Commissioner, T.C.
Memo. 1990-396, affd. without published opinion 935 F.2d 1280
(3d Cir. 1991); Cohen v. Commissioner, T.C. Memo. 1987-537.
Consequently, the knowledge or reason to know factor weighs
against granting petitioner relief.
The unpaid liability in this case is the result of, among
other things, petitioner’s and intervenor’s failure to file their
joint income tax returns for 1990 through 1995 and to pay their
income taxes for those years when they were due. All taxpayers
have a duty to file timely and accurate returns and to pay the
amounts shown as due on those returns. See generally secs. 6001,
6011(a), 6012(a)(1), 6072(a), 6151(a). Therefore, petitioner’s
reliance on intervenor to handle the preparation and filing of
their joint income tax returns does not establish that the
additions to tax and interest are solely attributable to
intervenor. Furthermore, petitioner has not denied that the
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