- 16 -
(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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