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received the refund in full, and petitioner used the moneys from
the refund to pay joint household liabilities.
Petitioner and Mr. Glaze’s 1995 joint income tax return was
prepared by Jackson Hewitt Tax Service. Petitioner “took all the
information from my [petitioner’s] tax return from Scottish Rite
Hospital, and the information that he [Mr. Glaze] had given me
from his tax returns” to the Jackson Hewitt Tax Service Center.
Petitioner reviewed the 1995 joint income tax return before
filing it with the Internal Revenue Service. Both petitioner and
Mr. Glaze voluntarily signed their 1995 joint income tax return.
On November 21, 1997, respondent issued petitioner and Mr.
Glaze a notice of deficiency for taxable year 1995, in which
respondent determined that they had unreported income of $36,424
and were liable for an income tax deficiency of $8,237, an
addition to tax pursuant to section 6651(a)(1) of $1,493, and an
accuracy-related penalty pursuant to section 6662 of $1,647.
Neither petitioner nor Mr. Glaze filed a petition with this Court
with respect to the notice of deficiency. Accordingly, on or
about April 6, 1998, respondent assessed the tax liability,
addition to tax, and the accuracy-related penalty that were
reflected in the notice of deficiency for taxable year 1995.
Petitioner and Mr. Glaze were divorced on May 26, 1999, by a
divorce decree entered by the Circuit Court of Shelby County,
Tennessee. The divorce decree refers to a “written Marital
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