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the large deductions contained in the return. The return was
prepared by a professional C.P.A., and petitioner had no reason
to question its correctness. See Price v. Commissioner, 887 F.2d
at 963; Shea v. Commissioner, 780 F.2d 561, 566 (6th Cir. 1986),
affg. in part and revg. in part T.C. Memo. 1984-310; Padgett v.
Commissioner, T.C. Memo. 1987-130 (noting the complexity of the
tax information and concluding that neither the spouse nor “any
reasonable person under her circumstances” could have analyzed
the transactions without “a sophistication in tax return
preparation which she did not have * * * and should not be
expected to have”). Further, petitioner has no background in
options trading. Even if she had reviewed the return, a large
trading loss would not have raised a red flag because the nature
of her husband’s option trading business was to lose and gain
millions of dollars at a time.
Respondent argues that petitioner had a duty to inquire
because the Campbells paid no tax for 1983 and received a refund
of $314,229. We disagree. Because of the complexity of the
transactions at issue and the fact that Mr. Campbell took
petitioner’s money without her knowledge, we would not expect her
to realize that Mr. Campbell was taking aggressive tax losses
against the gains in her account. See Resser v. Commissioner,
supra at 1538 (noting that “traders in highly volatile
instruments [could] expect to have large realized gains or losses
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