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their joint return for that year. However, petitioner’s
testimony is not relevant to the matter before this Court, as the
unreported income stems from petitioners’ rental property and an
annuity and not, as petitioner believes, from the Schedule C
activity.
Mr. Gilmer testified as to the couple’s business activity
during the year in issue. He admitted that he kept records for
all World Works Diversified activities and knew all of the
general details with respect to these activities with the
exception of the educational consulting activity, which he
claimed was under the sole purview of Ms. Payton. As previously
stated, petitioner testified that he prepared the 2001 tax return
in question and reported all of the expenses and claimed
deductions at issue in these cases. The detailed information
that petitioner provided this Court about the couple’s business
activities in 2001 illustrates to us that petitioner was, in
fact, aware of all income from the couple’s various business
endeavors.
Ms. Payton credibly testified that Mr. Gilmer was aware of
and participated in all of the couple’s business endeavors during
the year in issue. We believe Ms. Payton’s testimony that
petitioner had knowledge and overall oversight of all the
couple’s business activity and records pertaining to such
activity in 2001.
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