- 42 - 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.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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