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v. Commissioner, T.C. Memo. 1985-478; see, e.g., 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.
At the times in 1996 that petitioner signed the joint
returns for 1992 through 1995, petitioner was well aware of the
financial difficulties that had plagued her family since 1992.
In order to ease these difficulties, petitioner had entered the
workforce after being a homemaker for more than 20 years and had
accepted the risks of allowing a lesser amount of Federal income
tax to be withheld from her wages than that which would become
due on her portion of Mazzilli’s and her joint income and of not
filing Federal income tax returns during the years in issue.
Petitioner was also aware that foreclosure proceedings had been
commenced against Mazzilli and her and that they would lose their
home if they did not become current on their mortgage payments.
Under these facts and circumstances, petitioner has not
established 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.
Consequently, petitioner does not satisfy the knowledge or reason
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