Rosemarie Meyer - Page 16

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          (quoting Price v. Commissioner, supra at 965); Stevens v.                   
          Commissioner, 872 F.2d 1499, 1505 n.8 (11th Cir. 1989), affg.               
          T.C. Memo. 1988-63.  This test applies to both omissions from               
          income and erroneous deductions.  Stevens v. Commissioner, supra            
          at 1505 n.8.  Four factors considered relevant to the "reason to            
          know" test are:  (1) The relief-seeking spouse's level of                   
          education; (2) the relief-seeking spouse's level of participation           
          in family and business affairs; (3) the presence of expenditures            
          that appear lavish or unusual when compared with the family's               
          past levels of income, standard of living, and spending patterns;           
          and (4) the culpable spouse's evasiveness and deceit concerning             
          the couple's finances.  Friedman v. Commissioner, 53 F.3d at 531-           
          532 (citing Hayman v. Commissioner, 992 F.2d at 1261); Price v.             
          Commissioner, supra at 965.  No single factor or set of factors             
          is dispositive.  This Court does not make a determination merely            
          by adding factors favoring petitioner's position; rather, the               
          test is a subjective one.  Guth v. Commissioner, 897 F.2d 441,              
          444 (9th Cir. 1990), affg. T.C. Memo. 1987-522; see Langberg v.             
          Commissioner, supra.                                                        
               In both omitted income and erroneous deduction cases,                  
          spouses who fail to read the returns before signing them are                
          nonetheless charged with constructive knowledge of their                    
          contents.  Hayman v. Commissioner, 992 F.2d at 1262.  The Court             
          will not excuse a petitioner who neglects to review a return that           
          she signed under penalties of perjury.  Terzian v. Commissioner,            




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