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moving was excessive and that the actual cost was between $300 to
$500. She and her spouse had not employed a commercial house
mover but had rented a U-Haul trailer and a truck, which they
drove themselves. That exorbitant cost was also noted in Mr.
Clark’s case before this Court. Petitioner, therefore, knew or
should have known that these unexplained deposits were coming
from somewhere, i.e., her husband’s trade or business activity,
and also admitted the $35,304 deduction for moving expenses was
incorrect. Thus, for 1998, petitioner knew, in signing the
return, that there was an understatement of tax with respect to
the items discussed. Petitioner, therefore, is not entitled to
relief for 1998.
For the year 2000, the joint return included a Schedule C
for an Internet trade or business activity of Mr. Clark, which
petitioner was well aware of. On Schedule C for that year, the
reported gross income was $1,682, the expenses deducted were
$12,289, and the reported net loss was $10,607. Respondent
determined that the gross receipts from the activity were
$33,986.23 and that, during the course of the year, $11,019 was
transferred from the joint account petitioner had with her
husband to petitioner’s personal account. Thus, the $10,607 loss
from this Schedule C activity served to reduce petitioner and Mr.
Clark’s wage and salary income of $27,007, $24,906.91 of which
represented earnings of petitioner. Petitioner knew her husband
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