Nancy A. Sjodin - Page 7

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          believe that this rises to the level of abuse necessary to weigh            
          as a factor in petitioner’s favor.                                          
               Petitioner began filing separate returns in 1994 when she              
          discovered a lien on the house, and the Appeals officer noted               
          that she is currently in full compliance with Federal income tax            
          laws.                                                                       
               Respondent argues that petitioner had reason to know that              
          the liabilities shown on the returns she signed would not be                
          paid.  Petitioner testified that in order to file their returns,            
          Mr. Sjodin would collect her Forms W-2, Wage and Tax Statement,             
          and have an accountant complete the returns.  When the joint tax            
          returns were completed, petitioner signed them.  She did not                
          inquire into whether the tax shown as due was going to be paid.             
          This is not surprising, given the picture petitioner has painted            
          of the way her family dealt with finances.  Petitioner stated               
          that her job was to raise their four children, while Mr. Sjodin’s           
          job was to provide for the family.  She claims that in 40 years             
          of marriage, she has never written a check out of the joint                 
          checking account she shared with Mr. Sjodin.  Petitioner knew               
          nothing about the family finances and stated that Mr. Sjodin kept           
          the records locked in his home office.  She was not involved in             
          financial decisions, and Mr. Sjodin unilaterally chose and bought           
          their homes over the years.                                                 








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