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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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Last modified: May 25, 2011