Suzanne E. Barrera, a.k.a. Suzanne E. Battle - Page 40




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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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