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reason to know, about the purported wages from Premium Fresh
Juice, we must determine: (1) Whether the payroll checks issued
in petitioner’s name and deposited into petitioner and Mr.
Bennett’s joint bank account gave petitioner knowledge, or reason
to know, of the purported wages, (2) whether petitioner’s 1998
return, which reported these wages from Premium Fresh Juice, gave
petitioner knowledge, or reason to know, of the purported wages,
and (3) whether the Form W-2 issued to petitioner from Columbia
Cleaning (as payroll agent for Premium Fresh Juice) gave
petitioner knowledge, or reason to know, of the purported wages.
Although the payroll checks were issued in petitioner’s name
and deposited into joint accounts with her purported endorsement
signature, petitioner testified that she never saw, and certainly
did not endorse for deposit, the payroll checks. Further,
petitioner testified that she did not have access to monthly bank
statements and was forbidden by Mr. Bennett to access the
accounts. We found petitioner’s testimony to be credible and
trustworthy. Given Mr. Bennett’s position as general manager of
Premium Fresh Juice, and his control over their household and
14(...continued)
from Premium Fresh Juice are not wages. In addition, there is no
indication that petitioner’s purported wages were actually the
wages of Mr. Bennett. Accordingly, we do not impute to
petitioner knowledge of the $31,385 of purported wages reported
on her return by virtue of the fact that Mr. Bennett worked for
the company.
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