Janice L. Morris - Page 29

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          Commissioner, supra at 1536; Bokum v. Commissioner, 94 T.C. 126,            
          148 (1990), affd. 992 F.2d 1132 (11th Cir. 1993).  A spouse may             
          have a duty to inquire further if he or she knows enough facts so           
          as to be placed on notice of the possibility of a substantial               
          understatement.  Guth v. Commissioner, 897 F.2d 441, 444-445 (9th           
          Cir. 1990), affg. T.C. Memo. 1987-522.                                      
               Factors to be considered in determining whether petitioner             
          had no reason to know within the meaning of section 6013(e)(1)(C)           
               include the spouse's level of education; the spouse's in-              
               volvement in the financial and business activities of the              
               family; any substantial unexplained increase in the                    
               family's standard of living; and the culpable spouse's                 
               evasiveness and deceit about the family's finances. * * *              
               [Resser v. Commissioner, supra at 1536.]                               
               According to the notice, Mr. Morris embezzled $102,972.40,             
          $128,092.34, and $129,046.26 during the years 1987, 1988, and               
          1989, respectively, and, of the total embezzled funds, reported             
          $32,425 as gross receipts of Accu-Data during 1987, $54,907.13 as           
          the aggregate gross receipts of Accu-Data and Meadows during                
          1988, and $85,944.95 as the aggregate gross receipts of Accu-Data           
          and Meadows during 1989.                                                    
               During the years at issue, Mr. Morris deposited all of the             
          embezzled funds into the bank accounts of the following corpora-            
          tions and other entities that he controlled:  Accu-Data, Trust              
          768, Meadows, and MCIC.  Checks drawn on those accounts were                
          received by or were expended on behalf of petitioner during those           
          years, as follows:                                                          





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