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expenses. Petitioners make no argument with regard to section
6015(b)(1)(D) that it would be inequitable to hold Mrs. Kosinski
liable for the deficiencies in tax stated on petitioners’ 1997
joint return.
Mrs. Kosinski is a college graduate and has previous work
experience as a bank teller for two different banks. From 1995
through 1999, she cashed approximately $2.85 million in checks,
all in $9,500 increments, from petitioners’ personal and business
accounts. She cashed 87 checks totaling over $800,000 during
1997. Mrs. Kosinski testified that she did not know her
husband’s purpose for the cash withdrawn or what he did with it
once she gave it to him. On one occasion, at her husband’s
direction, she wrote a check to cash in the amount of $10,000 and
left the check in an envelope under a doormat for Phillips. She
testified that she never asked her husband why they were
withdrawing millions of dollars of cash in $9,500 increments from
their bank accounts.
Mrs. Kosinski testified that she did not know that checks
from T.J. Construction’s bank account rather than from
petitioners’ personal account were written to pay for
approximately $141,000 of improvements on petitioners’ home and
the home of petitioner’s mother between 1996 and 1998.
Mrs. Kosinski was aware of the extensive improvements being made
to her home, and the majority of the invoices from Rougewood
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