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employment in her husband's business.
Petitioner, unlike the taxpayer in Friedman v. Commissioner,
supra, was a college-educated stockbroker when she signed the
returns in issue, who admits that she failed to review those
returns prior to signing them. Petitioner's failure to review
the returns before signing them was apparently deliberate because
nothing in the record indicates that she could not have reviewed
them had she wished to do so. Petitioner claims that she signed
the returns because she trusted Mr. Crowley. That trust alone,
however, does not eliminate a spouse's duty to inquire when a
perusal of the return would indicate that further inquiry is
necessary. Hayman v. Commissioner, supra at 1262; Stevens v.
Commissioner, 872 F.2d 1499, 1507 (11th Cir. 1989), affg. T.C.
Memo. 1988-63. Consequently, we hold that petitioner has failed
to prove that she did not know and had no reason to know that the
deductions claimed on the returns for the taxable years in issue
would give rise to substantial understatements.16
Turning to petitioner's contention that she is eligible for
relief as an innocent spouse under the transitional rule,17 we
16
Our holding renders it unnecessary to consider whether
petitioner has satisfied the remaining contested requirement of
sec. 6013(e).
17
In Park v. Commissioner, 25 F.3d 1289, 1300 (5th Cir. 1994),
affg. T.C. Memo. 1993-252, the Court of Appeals for the Fifth
Circuit addressed the scope of the transitional rule as follows:
(continued...)
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