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We conclude that there are no special mental or physical health
factors in this case.
Petitioners’ briefs similarly overstate the record with
respect to Mrs. Chou’s lack of knowledge that the taxes would be
paid at the time she signed the return. Petitioners each
testified that Mr. Chou handled the family’s finances, consulted
with the accountant, and paid for the household expenses. They
also testified that they did not have any joint checking accounts
or credit cards. Mrs. Chou’s testimony about her state of mind
at the time that she signed the return was as follows:
Q [Mrs. Chou’s counsel] Do you remember looking
at the 2000 return when you signed it, do you remember
actually signing the 2000 return?
A [Mrs. Chou] I’m sure I signed it. I don’t
remember that specific one as different as the–-any
other particular year.
In relation to the OIC, petitioners had submitted a factual
statement asserting that they learned of the AMT liability in
March 2001. When she signed the joint income tax return in
April, the amount shown as owing, $1,928,732, appeared
approximately 1-1/2 inches above her signature. In her
Form 8857, Mrs. Chou did not claim that she did not know of the
liability. The July 27, 2005, statement that she submitted in
response to Dorr’s inquiry was similarly more cautious and candid
in asserting the state of her knowledge, to the effect that she
was aware of the increased taxes resulting from the stock options
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