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and reviewed at least the first three pages of that return with
petitioner and (2) informed her that they (a) owed $38,324 of tax
for 1998, (b) needed to make arrangements with the IRS to set up
an installment plan to pay that tax liability, and (c) needed to
start setting money aside, which Mr. Krasner told petitioner
would require reducing the amount that they were spending on
household and other items. Under these circumstances, we con-
clude that it was unreasonable for petitioner to believe when she
signed the 1998 joint return on April 10, 1999, that the $38,324
of tax shown due in that return would be paid by Mr. Krasner when
that return was filed. At a minimum, in light of what Mr.
Krasner told petitioner immediately before she signed the 1998
joint return, petitioner should have asked Mr. Krasner at that
time to explain why they were unable to pay their joint tax
liability for 1998, given that they had been spending money on
household and other items, including gifts for petitioner and
trips by petitioner, alone or with one or more family members,
during 1998 and the first several months of 1999. Petitioner
asked for no such explanation. Petitioner would have the Court
conclude that she asked for no such explanation because Mr.
Krasner never advised her on the day she signed the 1998 joint
return that, in order to be able to pay their $38,324 joint tax
liability for 1998, they needed to make arrangements with the IRS
to set up an installment plan and to start setting money aside by
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