Patricia A. Hendricks and John J. Hendricks - Page 15

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               Mr. Hendricks dominated the financial side of the marriage             
          with petitioner playing a minor role in the family’s finances.              
          Petitioner did not participate in any of Mr. Hendricks’s business           
          activities.  Although Mr. Hendricks was not deceitful regarding             
          their finances, he did not consult with petitioner about making             
          the investment in Boulder Oil and Gas and did not disclose that             
          the investment had been made.  Moreover, petitioner played a                
          minimal role in the preparation of the tax returns.  The only               
          information petitioner provided was a list of personal and                  
          household expenses.  She relied upon Mr. Hendricks to provide the           
          remainder of the information.                                               
               The Hendrickes have led frugal lifestyles.  We find no                 
          evidence in the record that the Hendrickses made any lavish or              
          unusual expenditures during the relevant years.                             
               Considering all of the circumstances concerning the joint              
          1983 tax return, a reasonably prudent taxpayer under petitioner’s           
          circumstances–-living a modest life, raising a family of five               
          children, uninvolved in the financial affairs of the family, and            
          without any financial background–-at the time of signing could              
          not be expected to know about the understatement attributable to            
          Mr. Hendricks’s investment in Boulder Oil and Gas.                          
               Is there, however, a duty of inquiry?  In order for                    
          petitioner’s duty of inquiry to arise, she must first harbor                
          doubts about the accuracy of the return.  Stevens v.                        

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