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returns had she wanted to do so. Yet petitioner never reviewed
the joint returns before she signed them, and she never asked Mr.
Barrera about paying the reported liabilities because, as she
admitted, she “wouldn’t have even looked at the tax return[s] to
see if anything was due, to begin with.” Petitioner testified
that she “signed blindly” because she trusted that Mr. Barrera
“would do the best” for her and her family. Based on the instant
record, we find that petitioner essentially, and admittedly,
turned a “blind eye” toward the filing of the 1998, 1999, and
2000 joint tax returns and the failure to pay the taxes shown
thereon.
A taxpayer who signs a return without reviewing it is
charged with constructive knowledge of its contents, including
the tax due shown on that return. Hayman v. Commissioner, supra
at 1262; see also Park v. Commissioner, 25 F.3d 1289, 1299 (5th
Cir. 1994), affg. T.C. Memo. 1993-252; Castle v. Commissioner,
T.C. Memo. 2002-142; Cohen v. Commissioner, T.C. Memo. 1987-537.
Thus, despite the fact that petitioner signed the 1998, 1999, and
2000 joint returns without reviewing them or discussing them with
Mr. Barrera, she should have known of the taxes shown due
thereon.
Having found that petitioner had constructive knowledge of
the taxes shown due on the 1998, 1999, and 2000 joint returns, we
further find that, under the facts of this case, it was not
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