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should have known that the return contained a substantial
understatement. Hayman v. Commissioner, 992 F.2d at 1261.
According to Hayman, a court should look at (1) The level of
education and (2) the knowledge and experience in the family's
business and financial affairs attained by the spouse claiming to
be innocent; (3) whether the family's current standard of living
was lavish compared to past levels of income and expenditures;
and (4) the conduct of the culpable spouse in concealing the true
state of the family's finances from the "innocent" spouse.
Friedman v. Commissioner, supra at 531-532.
We have made detailed findings of fact, many of which
encompass the Hayman case factors, and no useful purpose is
served by rehashing these facts in detail. But in our view, when
the Hayman four factors are applied in our case, petitioner
satisfies the requirement of subparagraph (C) that in signing the
return she did not know, and had no reason to know, that there
were substantial understatements.
(1) Petitioner, while well educated, devoted most of her
time to her interest in the arts--graphic arts and the theater--
and her work experience as a space salesman for a small, local
newspaper did nothing to fit her for an understanding of business
matters on anything like a sophisticated level.
(2) Petitioner had no role whatever in the family's
financial affairs beyond, at most, making cash payments for
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