Julie C. Nichols, n.k.a. Julie C. Amrein - Page 7

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               In view of petitioner’s admitted execution of the                      
          Certificate of Marital Status, which expressly referred to                  
          Nichols’s Lottery Prize Assignment Agreement, we cannot conclude            
          that she did not know or have reason to know that there was an              
          understatement on a tax return that did not report the proceeds             
          of the sale of the lottery rights.                                          
               Moreover, respondent has established that petitioner had               
          actual knowledge of the item giving rise to the deficiency at the           
          time that she signed the return.  Although petitioner disavows              
          involvement with the transaction and with the return preparation,           
          she has not established that she signed the return under duress.            
          Petitioner testified:                                                       
                    It was not uncommon for me to take paper from my                  
               ex-husband’s business during our marriage.  I would                    
               take them next to Cheryl Coleman, who was a realtor,                   
               and she would notarize statements.  I never read the                   
               statements I was filing.  I would make deposits at his                 
               bank.  This was the only involvement I had with his                    
               business.                                                              
          Petitioner’s argument that she did not read what she was signing            
          is unpersuasive and unavailing.  She was articulate in presenting           
          her case at the time of trial, and she was obviously able to                
          function in a normal manner despite her claimed medical                     
          disabilities.  She cannot be excused from the implications of the           
          Certificate of Marital Status, and she has not satisfied the                
          requirements for relief from joint and several liability.                   








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