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In order to satisfy the knowledge or reason to know element
of Rev. Proc. 2000-15, sec. 4.02, 2000-1 C.B. at 448, petitioner
must establish that it was reasonable for her to believe that
Mazzilli would pay the amounts shown as due on the joint returns
for 1992 through 1995 at the times that she signed them.
Petitioner cannot rely on her lack of awareness of the amounts
shown as due on these returns to establish that it was reasonable
for her to believe that Mazzilli would pay these amounts. By
signing the joint returns for 1992 through 1995, petitioner is
charged with constructive knowledge of, inter alia, the amounts
shown as due on those returns. Hayman v. Commissioner, 992 F.2d
1256, 1262 (2d Cir. 1993), affg. T.C. Memo. 1992-228; see also
Park v. Commissioner, 25 F.3d 1289, 1299 (5th Cir. 1994), affg.
T.C. Memo. 1993-252. Furthermore, petitioner’s unquestioning
reliance on Mazzilli to handle the preparation and filing of the
joint returns for 1992 through 1995 does not establish that it
was reasonable for her to believe that Mazzilli would pay the
amounts shown as due on these returns at the times that she
signed them. 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).
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
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