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Abuse
Respondent contends that this factor is neutral. We agree.
At no time was petitioner abused by Mr. Butner.
Knowledge or Reason To Know
Petitioner contends that she did not know and had no reason
to know when she signed the respective joint income tax returns
for the taxable years 1994, 1995, 1998, and 1999 that the respec-
tive liabilities reported in those returns would not be paid.
The record does not establish, and petitioner does not contend,
that she signed those returns under duress, and not voluntarily.
Petitioner testified on cross-examination that she believed that
the joint income tax return that she and Mr. Butner filed for
each of the taxable years at issue was correct when she signed
each such return.15
Moreover, petitioner did not answer the questionnaire that
respondent’s representative asked her to complete as it pertained
to whether she was aware of the liability reported in the joint
income tax return that she and Mr. Butner filed for each of the
years at issue and whether she thought that the liability shown
15Even if petitioner signed each of the returns in question
without reviewing it, petitioner is charged with constructive
knowledge of the tax shown due in each such return. Park v.
Commissioner, 25 F.3d 1289, 1299 (5th Cir. 1994), affg. T.C.
Memo. 1993-252; see also Castle v. Commissioner, T.C. Memo.
2002-142; Cohen v. Commissioner, T.C. Memo. 1987-537 (the provi-
sions providing relief from joint and several liability are
"designed to protect the innocent, not the intentionally igno-
rant").
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