- 19 - Commissioner, 992 F.2d 1256, 1262 (2d Cir. 1993), affg. T.C. Memo. 1992-228. As noted below, Gerald assured petitioner that everything was in order, and she relied on Gelda's reputation as return preparer. We look at the following four factors to determine whether a reasonably prudent taxpayer in petitioner's position should have known that the return contained a substantial understatement: (1) Petitioner's level of education; (2) petitioner's knowledge and experience in the family's business and financial affairs; (3) whether the family's standard of living during the years in issue 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 petitioner. Friedman v. Commissioner, supra at 531-532. Petitioner graduated from high school and completed two semesters of college. She had no training or experience in business matters. Petitioner has worked in the home since 1966. Petitioner's knowledge of the family's financial affairs and Gerald's business affairs was minimal. Petitioner paid household expenses from a joint checking account, and that was her only involvement in the family's financial affairs. Petitioner had no voice in the Jacobys' investments, and she was not aware that Gerald had invested in tax shelters. She had no role in Gerald's businesses, and he would not discuss his business activities with her.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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