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Commissioner, T.C. Memo. 2004-52; Wiest v. Commissioner, T.C.
Memo. 2003-91; see also Rev. Proc. 2000-15, sec. 4.02(1)(b),
2000-1 C.B. at 448. Additionally, if a taxpayer knows enough
facts to be put on notice of the possibility of an underpayment,
the taxpayer has a duty to inquire further to determine the
amount of his or her tax liabilities. See Chou v. Commissioner,
T.C. Memo. 2007-102; Motsko v. Commissioner, T.C. Memo. 2006-17;
Feldman v. Commissioner, T.C. Memo. 2003-201, affd. 152 Fed.
Appx. 622 (9th Cir. 2005). A taxpayer is not relieved of this
duty of inquiry solely because the taxpayer relied on his or her
spouse to take care of the tax returns. See Hayman v.
Commissioner, 992 F.2d 1256, 1262 (2d Cir. 1993), affg. T.C.
Memo. 1992-228; Morello v. Commissioner, supra. A taxpayer
cannot obtain the benefits of relief from joint and several
liability simply because the taxpayer turned a “blind eye” by not
reviewing the contents of a joint return and then failed to make
further inquiry into the ultimate tax liability shown on the
return. Price v. Commissioner, 887 F.2d 959, 965 (9th Cir.
1989), revg. an Oral Opinion of this Court; Levin v.
Commissioner, T.C. Memo. 1987-67.
In the instant case, Mr. Barrera never physically or
otherwise prevented petitioner from paging through the joint
returns for the years in issue, and petitioner admitted in her
testimony that she was “sure” she could have looked through the
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