Research should be memo and  should include thefollowing five sections:

(1) Facts, (2) Issue, (3) Authorities, (4) Conclusion, and (5)Analysis.

Scenario. Mary and John were married during the years at issue(i.e., years 2014, 2015, and 2016). They separated in 2016 anddivorced in 2017 after nearly 20 years of marriage. At the timeMary filed her petition, she resided in Maryland. She holds a highschool diploma and attended the University of Delaware for sixmonths, taking noncredit courses in the data processing. Whilemarried, Mary and John owned the marital home, two rentalproperties and a farm. As having a large blended family, they owneda large van in addition to two pickup trucks and an OldsmobileCutlass, which John described as a "classic car". They took familyvacations each year, including trips to Bermuda and Mexico. Theyenjoyed camping, and throughout the years they purchased severalcampers, which they used on family camping trips every few months.John owned VIP Builders, which was the primary source of thefamily's income. Established in the early 1990s, VIP Builders is ahome improvement company focusing on residential remodeling. Acarpenter by trade, John operated the business, but he did not havethe bookkeeping background to maintain the company's records. Hehired Mary to be the company's bookkeeper and office manager. Theirrelationship blossomed, and they eventually wed. Mary was VIPBuilders' bookkeeper/office manager for approximately 20 years,including the years at issue. She developed and maintained theaccounting program used by the business. Her duties included: (1)managing the company's financial records, bank accounts, andAmerican Express credit card account; (2) managing the company's"end of the month check run", which reconciled all charge accountsthat VIP Builders had from its vendors, roofing suppliers, lumberyards, plumbing supply houses, and other subcontractors; (3)reconciling the company's bank and credit card statements; (4)managing the accounts payable and accounts receivable; (5) trackinginventory; and (6) managing the company's payroll. To these ends,Mary had the authority to write and sign checks on behalf of VIPBuilders, deposit money into the company's accounts, and preparechecks and receipts for the business. Mary was familiar with VIPBuilders' clients and knew, or at least could have learned, theamounts they paid the company. Before becoming VIP Builders'bookkeeper, she had other experience in accounting. When Marymanaged VIP Builders' finances, her duties included the end-of-yearaccounting for the company. She reviewed the company's books andprovided information and documents to the company's certifiedpublic accountant (C.P.A.), Joe Taigi, who prepared Mary and John'sjoint tax returns. Mary also met and interacted with Mr. Taigiduring the years involved. She admitted to "booking things wrong"for VIP Builders and was advised that she had done so by Mr. Taigi.2 For 2014 Mary and John's joint returns underreported incomeattributable to VIP Builders; for 2015 the returns underreportedincome and overstated expenses attributable to VIP Builders. TheIRS made no adjustments with respect to VIP Builders for 2016. Inaddition to working for VIP Builders, Mary operated a horse careand boarding business on the farm that she and John owned. Sheexclusively controlled the business, and under her stewardship, thebusiness' income for each of the years involved was underreported.All adjustments made by the IRS for 2016 were due to underreportedincome with respect to the horse care and boarding business. Marywrote checks drawn on VIP Builders' bank account to herself, andshe used the VIP Builders' American Express credit card to payhorse care and boarding business and household expenses. Mary wasgiven the joint income tax returns for 2014, 2015, and 2016 beforethey were filed, but she did not review them before signing them.Mary was not a victim of spousal abuse or domestic violence duringthe years involved. The IRS tries to collect the joint taxliabilities of years 2014-2016 from Mary. Instruction: Provide youradvice to Mary who is appealing the case.