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1989), affg. T.C. Memo. 1988-63; Butler v. Commissioner, 114 T.C.
276, 284 (2000); Flynn v. Commissioner, 93 T.C. 355, 365-366
(1989).
Petitioner was not involved in managing her family’s
finances, making financial decisions for her family, or the
reporting of any tax consequences of financial decisions that
were claimed in the joint tax returns. Mr. Scott prepared the
Scotts’ Federal income tax returns for all years they were
married. Mr. Scott was an accountant who worked for an
accounting firm and who prepared returns for other taxpayers.
Petitioner, by contrast, had a high school education and worked
part time as a substitute clerk or secretary and a shipper. She
never prepared a tax return.
Petitioner never questioned Mr. Scott about the returns and
never questioned that he would pay the taxes reported on the
returns. It appears that, while money had always been tight, Mr.
Scott had paid the taxes shown as owed on the returns for all the
15 years of the Scotts’ marriage before the years at issue.
The liability for 1990 arises from a deficiency attributable
to the disallowance of deductions related to the Scotts’ Karnival
Klassics activity. Mr. Scott kept the records for that activity.
He presented the joint return to petitioner and told her where to
sign. He did not give petitioner the opportunity to examine the
1990 Schedule C, Profit or Loss from Business, for Karnival
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