- 23 - Petitioner was an enterprising individual, savvy enough in business affairs and bookkeeping to have built the successful businesses that she operated. We are satisfied, based on the record in the instant case, that petitioner had the ability to understand that there was a substantial understatement on the 1981 return and that she was sufficiently put on notice that she needed to inquire further into the partnership deductions generating the understatement. Consequently, we hold that petitioner has failed to prove that she did not have reason to know that there was an understatement of tax on the return for the 1981 taxable year and that petitioner is therefore not entitled to relief as an innocent spouse under section 6013(e).6 To reflect the foregoing, Decision will be entered under Rule 155. 6 Because we hold that petitioner had reason to know of the understatement, we need not address the questions of whether the Choate Square partnership deductions were grossly erroneous or whether it would be inequitable to hold petitioner liable for the deficiency attributable to the understatement.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011