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assume that, if she had been asked, she would have been truthful.
In the absence of further explanation, it is improbable that
Mrs. Chou did not know that, rather than paying the tax,
petitioners would be challenging their liability. She certainly
did not satisfy her well-established duty of inquiry. See, e.g.,
Albin v. Commissioner, T.C. Memo. 2004-230; Demirjian v.
Commissioner, T.C. Memo. 2004-22 (and cases cited therein). On
the entire record, we conclude that Mrs. Chou knew or had reason
to know that the tax would not be paid at the time that she
signed the return. We do not question petitioners’ allocation of
responsibility for family matters between themselves, but they
have not shown that Mrs. Chou should be relieved of their joint
liability on the 2000 return.
We have reviewed the other arguments of the parties. They
are without merit, irrelevant, or moot.
An order of dismissal with
respect to 2001 and a decision for
respondent will be entered.
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