Barbara A. Vriner, A.K.A. Barbara A. Coyne - Page 5

          spouse from relief.  Stevens v. Commissioner, 872 F.2d 1499, 1504           
          (11th Cir. 1989), affg. T.C. Memo. 1988-63; Bokum v.                        
          Commissioner, 94 T.C. 126, 138 (1990), affd. 992 F.2d 1132 (11th            
          Cir. 1993).  It is undisputed that the Vriners filed a joint                
          return and that the return contained a substantial understatement           
          of tax attributable to grossly erroneous items of Mr. Vriner.               
          Respondent argues, however, that petitioner knew or had reason to           
          know of the substantial understatements, and that it would not be           
          inequitable to hold her liable for the deficiency.                          
               Petitioner testified that she signed the 1987 Federal income           
          tax return after being directed to do so by Mr. Vriner, and we              
          are convinced that petitioner was not familiar with the contents            
          of the return.  We find that petitioner had no actual knowledge             
          of the substantial understatement of tax and, indeed, had no                
          knowledge of her husband's alleged narcotics activities prior to            
          the search of their home in 1988.  Thus, we must ascertain                  
          whether she had reason to know of the substantial understatement            
          of tax.                                                                     
               A taxpayer has reason to know of a substantial                         
          understatement of tax if a reasonably prudent taxpayer in his or            
          her position could be expected to know that the stated tax                  
          liability was erroneous or that further investigation was                   
          warranted.  Kistner v. Commissioner, 18 F.3d 1521, 1525 (11th               
          Cir. 1994), revg. and remanding T.C. Memo. 1991-463; Stevens v.             
          Commissioner, supra at 1505; Bokum v. Commissioner, supra at 153.           

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