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Despite her assumption, however, we cannot find that, at the time
the returns were signed, petitioner had no reason to know that
the reported taxes would not be paid. Petitioner completed
courses in accounting, finance, and business law, among others,
in the process of earning her bachelor’s degree in business
management. She has work experience in a professional capacity,
most notably as a loan officer assisting individuals with the
completion of their residential mortgage loan applications.
Thus, petitioner is neither uneducated nor unsophisticated as to
financial matters. Additionally, nothing in the record suggests
that Mr. Barrera deceived petitioner or concealed information
from her regarding family finances. Although petitioner contends
on brief that, after the close of his mortgage brokerage
business, Mr. Barrera was paying family living expenses with
credit cards without her knowledge, we do not find this
indicative of any deceit or concealment on Mr. Barrera’s part,
particularly in light of petitioner’s consistent testimony that
she never asked Mr. Barrera about family finances because “it was
just not * * * [her] concern”, and she never discussed paying
bills with Mr. Barrera because “[t]hat was his job, and my job
was to raise my children.” Moreover, petitioner admitted in her
testimony that, although Mr. Barrera “always lived the life that
everything was fine”, she knew things were changing financially
by at least 1999.
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