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petitioner argues that, because her area of expertise is limited
to the study of fabrics and clothing, rather than business and
accounting, we should attribute little if any weight to her
academic degrees and status as a professor. We reject
petitioner's efforts to attenuate her academic accomplishments by
pointing to the nature of her expertise. Based on the record in
the instant case, we are satisfied that a reasonably prudent
taxpayer with petitioner's education would have had the ability
to understand that there was a substantial understatement on each
of the joint returns. While it is not uncommon for courts to
conclude that highly educated intelligent taxpayers are entitled
to innocent spouse relief, cf. Resser v. Commissioner, 74 F.2d
1528 (7th Cir. 1996); Friedman v. Commissioner, 53 F.3d 523 (2d
Cir. 1995) ; Foley v. Commissioner, T.C. Memo. 1995-16; Robertson
v. Commissioner, T.C. Memo. 1992-32, the facts of the instant
case do not support a similar conclusion. We do not believe that
it was necessary for petitioner to have possessed specialized
knowledge and education in order for her to have had reason to
know income was being omitted from her joint returns. This case
does not involve transactions the nature of which would require
special understanding or knowledge to appreciate. Rather, it
involves the omission of embezzlement income. Cf. Resser v.
Commissioner, supra. That Mr. Peterson's law practice may have
been complex in nature, and despite petitioner's professed lack
of knowledge with respect to the operation of that practice, is
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