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that petitioner reasonably believed that Mr. Meadows would pay the
tax liability reported on the 1999 joint return.
It appears from the record that petitioner filed tax returns
for at least the preceding 3 years as a married taxpayer filing
separately. Petitioner testified that Mr. Meadows prepared those
returns for her and that she merely signed them. On one occasion,
Mr. Meadows signed her name to the return. Petitioner testified
that Mr. Meadows convinced her that it would be advantageous to
them to file a joint return for 1999, even though at the time the
return was due they were contemplating divorce. Petitioner
asserts that at Mr. Meadows’s request, she signed the joint 1999
return while it was blank; i.e., before any figures appeared on
it. Petitioner testified that in doing this, she “should have
known better than to trust” Mr. Meadows. According to petitioner,
Mr. Meadows then filed the return, which showed the tax liability
and the balance still owed. The address on the tax return was a
mailbox to which Mr. Meadows had access but petitioner did not.
Consequently, petitioner testified that she was unaware of any
further developments or correspondence from respondent pertaining
to the 1999 tax year and did not obtain a copy of the joint return
until respondent began collection efforts.
Petitioner could not reasonably have believed that Mr.
Meadows would pay the reported tax liability because petitioner
was unaware they had any tax liability, having signed a blank
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