Janice and Jacob were married during the years at issue (i.e., years 2014, 2015, and 2016). They separated in 2016 and divorced in 2017 after nearly 20 years of marriage.

At the time Janice filed her petition, she lived in Maryland. She has a high school diploma and attended the University of Delaware for 6 months, taking non-credit classes in the data processing. While married, Janice and Jacob purchased/owned the marital home, 2 rental properties, and a farm. Since having a large blended family, they possessed a large van, 2 pickup trucks, and an Oldsmobile Cutlass, which Jacob depicted as a "classic car". They took family vacations each year, including traveling to Mexico and Bermuda. They take pleasure in camping, and all through the years, they acquired a few campers, that they used on family camping trips every few months.

Jacob possessed VIP Builders, which was the dominant/primary source of income for the family. Founded in the early 1990s, VIP Builders is a home improvement company that focuses on residential remodeling. A carpenter by trade, Jacob managed the business, however, he did not have any bookkeeping background to manage and maintain the company's records. He employed Janice to be the bookkeeper and office manager for the company. Their relationship bloomed, and eventually, they wedded.

Janice worked as a bookkeeper and office manager at VIP Builders for approximately 20 years, including the years at issue. Janice developed and managed the accounting program used by the business. Her duties included: (1) managing the financial records, bank accounts, and American Express credit card account for the company; (2) managing the "end of the month check run", which reconciled all charge accounts that VIP Builders had from its vendors, roofing suppliers, lumber yards, plumbing supply houses, and other subcontractors (for the company); (3) reconciling its bank and credit card statements; (4) managing the A/P and A/R; (5) tracking inventory; and (6) managing the company's payroll. To these ends, Janice had the authority to write and sign checks on behalf of VIP Builders, deposit money into the company's accounts, and prepare checks and receipts for the business. Janice was familiar with VIP Builders' clients and knew, or at least could have learned, the amounts they paid the company. Previous to becoming VIP Builders' bookkeeper, she had other experience in accounting.

When Janice managed VIP Builders' finances, her duties included the end-of-year accounting for the company. She reviewed the company's books and provided information and documents to the company's C.P.A., Mark Taigi, who prepared Janice and Jacobs joint tax returns. Janice also met and interacted with Mr. Taigi during the years involved. She admitted to "booking things wrong" for VIP Builders and was advised that she had done so by Mr. Taigi. For 2014 Janice and Jacob's joint returns under-reported income attributable to VIP Builders; for 2015 the returns under-reported income and overstated expenses attributable to VIP Builders. The IRS made no adjustments with respect to VIP Builders for 2016.

In addition to working for VIP Builders, Janice operated a horse care and boarding business on the farm that she and Jacob owned. She controlled the business exclusively, and under her stewardship the business' income for each of the years involved was under-reported. All adjustments made by the IRS for 2016 were due to under-reported income with respect to the horse care and boarding business. Janice wrote checks drawn on VIP Builders' bank account to herself, and she used the VIP Builders' American Express credit card to pay horse care and boarding business and household expenses. Janice was given the joint income tax returns for 2014, 2015, and 2016 before they were filed, but she did not review them before signing them. Janice was not a victim of spousal abuse or domestic violence during the years involved. The IRS tries to collect the joint tax liabilities of years 2014-2016 from Janice.

Please give/provide advice to Janice who is appealing the case.