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that she take a $20,000 early withdrawal from her IRA or, as she
testified, she would “end up under a bridge”. Also in 2000,
petitioner returned to work at a job outside the home for the
first time in her marriage to Mr. Barrera since her pregnancy
with their first child in 1996.
In light of the foregoing, we cannot conclude that it was
reasonable for petitioner to believe that Mr. Barrera would pay
three income tax bills in the approximate amounts of $3,700,
$2,900, and $3,700. Although these unpaid amounts may have not
been significant enough to cause petitioner concern in the early
years of her marriage to Mr. Barrera, when his yearly adjusted
gross income was approximately $199,000 and his mortgage
brokerage business was operating, by the time she signed the
1998, 1999, and 2000 joint returns in May 2000, November 2000,
and July 2001, respectively, when petitioner and Mr. Barrera’s
reported adjusted gross income for a family of four was down to
$14,165 for 1999, $24,446 for 2000, and $2,108 for 2001, the
unpaid amounts were significant enough to put a reasonable person
in petitioner’s circumstances on notice that further inquiry
about their payment was warranted.
At trial, petitioner testified that had she seen the tax
amounts reported as due on the returns for the years in issue,
she would have assumed that Mr. Barrera would pay them. We have
no reason to doubt petitioner’s truthfulness on this matter.
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