Estate of Mark R. Woodward, Deceased, Lillian H. Woodward, Executrix, and Lillian H. Woodward - Page 13

          reasonably be expected to question an application for refund that           
          purports to eliminate all Federal income tax liability for 2                
          previous taxable years.  We conclude that petitioner's                      
          educational level was such that, if she had examined the 1983               
          income tax return or application for refund, she would have                 
          recognized that substantial understatements might exist or that             
          further investigation was warranted.                                        
                    (ii) Petitioner's involvement in the family's financial           
                         affairs                                                      
               Another factor to consider is petitioner's involvement in              
          the family's financial affairs.  Petitioner and Mr. Woodward                
          maintained a joint checking account.  Prior to Mr. Woodward's               
          retirement, petitioner shared responsibilities in matters                   
          relating to household expenses such as paying bills.  After his             
          retirement, and for the year in question, 1983, Mr. Woodward was            
          responsible for both the family's financial planning and for all            
          matters concerning household expenses.  Mr. Woodward did not                
          prevent petitioner from taking part in financial matters; rather,           
          petitioner chose not to participate in the financial affairs and            
          trusted her husband to handle them.  As petitioner shifted the              
          responsibility for financial matters to Mr. Woodward, she cannot            
          claim a lack of knowledge of these affairs as a basis for                   
          receiving innocent spouse protection where she was under a duty             
          to inquire into the legitimacy of the tax deductions and credits            
          claimed.                                                                    
               Although petitioner could not operate the computer on which            
          the financial records were kept, she could have asked her husband           



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