- 33 - due in each such return would be paid at the time of such filing. Nonetheless, in response to the very next question in that questionnaire, which sought a description of any plan that she and Mr. Butner had for paying any liability that was shown due in the joint income tax return for each of the years at issue and that was not paid at the time of filing each such return, petitioner admitted that there was no plan for paying any such liability. Furthermore, in 1996, before petitioner and Mr. Butner filed a joint income tax return for any of the taxable years 1994, 1995, 1998, and 1999, the Bankruptcy Court entered judgments in excess of $3 million against them. At the time of the trial in this case, those judgments had not been satisfied. Petitioner was aware that those judgments had been entered against Mr. Butner and herself and had not been satisfied when she signed (1) on January 20, 1998, the respective joint income tax returns for the taxable years 1994 and 1995 and (2) on October 14, 2000, the respective joint income tax returns for the taxable years 1998 and 1999. In addition, although petitioner testified that she had no reason to believe at the time she signed the joint income tax return for each of the years at issue that the tax shown due in each such return would not be paid and that she thought her husband "was going to take care of that", on April 24, 1995, aPage: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: November 10, 2007