Charles L. Fields and Barbara S. Fields - Page 42

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          dealings with oil and the extent and magnitude thereof.  Among              
          other things, we find that Mrs. Fields knew that petitioner                 
          worked as a consultant for Ashland, that he was attempting to               
          secure crude oil for Ashland, that he traveled abroad extensively           
          using his various contacts to locate a source of oil, that he               
          traveled on business to Bermuda and Cameroon, and that his                  
          business pursuits involved Ashland, oil, and a Government                   
          official from Cameroon.                                                     
               Even if we were to conclude (which we do not) that she did             
          not know of petitioner's activities at the relevant times, we               
          believe that she certainly should have known of the                         
          understatement of income on each of the returns when she signed             
          them.  Mrs. Fields is well educated and intelligent.  She was               
          actively involved in the family's business and financial affairs.           
          She knew of the magnitude of petitioners' spending during the               
          relevant years, including extraordinary expenditures (e.g.,                 
          purchase of a boat, purchase and renovation of homes), and she              
          knew that the money to pay for these expenses did not come from             
          petitioners' checking account.  A prudent person in Mrs. Fields'            
          position would have known that the returns were erroneous or that           
          further inquiry was warranted.  Perfect knowledge of the family's           
          financial affairs is not required to satisfy the reason to know             
          standard.  Shea v. Commissioner, 780 F.2d 561, 567 (6th Cir.                
          1986), affg. in part and revg. in part T.C. Memo. 1984-310.                 






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