Jeffrey Chou and Cindy Chou - Page 23




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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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