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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