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Tides, Inc., Georgetown Square, and the Three Crowns Hotel Back
Court that we assume arguendo gave rise to a portion or all of an
understatement for one or more of the taxable years 1989, 1991,
1992, and 1993. We note initially that petitioner contends
inconsistently (1) that she did not know, and had no reason to
know, about Mr. Monsour’s investments and (2) that she knew about
Mr. Monsour’s investments. We reject petitioner’s claim that she
did not know, and had no reason to know, about Mr. Monsour’s
investments. Petitioner does not contend, and the record does not
establish, that Mr. Monsour was evasive and deceitful with her
concerning Mr. Monsour’s investments or the joint investments of
petitioner and Mr. Monsour. Before their marriage on July 3,
1983, petitioner and Mr. Monsour entered into a prenuptial agree-
ment which listed all of Mr. Monsour’s assets. At all relevant
times, petitioner reviewed and mailed the checks that Mr. Monsour
signed with respect to Mr. Monsour’s investments as well as checks
with respect to the joint investments of petitioner and Mr.
Monsour. Moreover, at all relevant times, including throughout
the taxable years at issue, petitioner knew about Mr. Monsour’s
monthly trips to check on his Florida investments, and sometimes
she traveled with him on those trips. At a time not disclosed by
the record after 1986, petitioner questioned Mr. Monsour about
whether Mr. Monsour’s Florida investments were worthwhile, to
which he responded that they were. In addition, in signing each
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