Patti Ann Ollestad - Page 10

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          United States, 509 F.2d 162, 166-167 (5th Cir. 1975); Terzian v.            
          Commissioner, 72 T.C. 1164, 1170 (1979).  We conclude that a                
          reasonably prudent person in petitioner's position would not                
          have had reason to know of the unreported community income from             
          Trucking during the years at issue.                                         
               In arriving at this conclusion, we emphasize that petitioner           
          did not complete the ninth grade and was not sophisticated with             
          respect to financial or tax matters.  Prior to and during her               
          marriage, petitioner did not hold a job.  Apparently, she had no            
          experience with paychecks or income taxes and never filed an                
          income tax return.  Moreover, there is no indication of lavish or           
          extravagant expenditures that might have given petitioner reason            
          to know of the unreported income.  Rather, petitioner lived a               
          modest lifestyle.                                                           
               Trucking was a partnership between Mr. Thompson and his                
          father.  Petitioner was unfamiliar with the financial condition             
          and business operations of Trucking.  Taxation of income from a             
          partnership is far more complicated than the taxation of an                 
          employee's wages.  A partner's income is based upon his or her              
          "distributive share" of a partnership's tax items.  Sec. 702(a).            
          Without going into an elaborate explanation of partnership                  
          accounting, we merely note that a partner might have take-home              
          money, without having taxable income from the partnership; e.g.,            
          a draw.  Consequently, petitioner did not have reason to know of            

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