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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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