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1298. See Sanders v. United States, 509 F.2d 162, 168 (5th Cir.
1975). Even complete deference to the husband’s judgment and the
alleged innocent spouse’s role as a traditional homemaker will
not always sustain an innocent spouse claim. See, e.g., Stevens
v. Commissioner, 872 F.2d 1499, 1505-1506 (11th Cir. 1989), affg.
T.C. Memo. 1988-63. “[A] spouse seeking innocent spouse relief
cannot turn ‘a blind eye’ to, by preferring not to know of, a
deduction fully disclosed on a return when the amount of that
deduction is so large that it would reasonably put her on notice
that she should inquire further.” Park v. Commissioner, supra at
1299.
Significant factors to an analysis of the innocent spouse
claim are the taxpayer’s level of education, the taxpayer’s
experience in business affairs and bookkeeping, the taxpayer’s
level of involvement in the family’s financial affairs, the
presence of expenditures that appear lavish or unusual when
compared to the taxpayer’s past standard of living, the
“culpable” spouse’s openness concerning the family finances,
whether the tax treatment of the transaction in issue was hidden
in the recesses of the return, whether the taxpayer relied on an
expert, and whether the taxpayer reviewed the return. Park v.
Commissioner, supra at 1298-1299; Sanders v. United States, supra
at 167; Bokum v. Commissioner, 94 T.C. 126, 146-149 (1990), affd.
992 F.2d 1132 (11th Cir. 1993). We consider the interplay among
the various factors. Different factors will predominate in
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