Estate of Mark R. Woodward, Deceased, Lillian H. Woodward, Executrix, and Lillian H. Woodward - Page 16

          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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