which she cannot escape by simply ignoring its contents"), affg.
T.C. Memo. 1993-252; see also Lauer v. Commissioner, T.C. Memo.
1994-579 ("a taxpayer is not permitted to obtain the benefits of
section 6013(e) by turning a blind eye to--by preferring not to
know of--facts clearly within his or her grasp, or fully
disclosed on a return that the taxpayer signed"); McComb v.
Commissioner, T.C. Memo. 1994-577 ("A spouse may not obtain
protection as an innocent spouse in deduction cases by turning a
blind eye to facts fully disclosed on a return which, if she had
looked at the return, would reasonably have put her on notice
that further inquiry was needed").
3. Conclusion
We hold that petitioner, in signing the 1983 Federal income
tax return and application for refund, had reason to know, within
the meaning of section 6013(e)(1)(C), of the substantial
understatements of income tax for 1980 and 1981. Because we so
hold, we need not address whether it would be equitable or
inequitable to hold petitioner liable for the deficiencies in tax
attributable to those understatements.
In view of the foregoing, we sustain respondent's
determination that petitioner is liable for the deficiencies in
tax and additions to tax as set forth in the notice of
deficiency. Sec. 6013(d)(3).
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