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has a duty to inquire further. 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 the spouse
had reason to know are the alleged innocent spouse's level of
education; the spouse's involvement in the family's business and
financial affairs; the presence of expenditures that appear
lavish or unusual when compared to the family's past levels of
income, standard of living, and spending patterns; and the
culpable spouse's evasiveness and deceit concerning the couple's
finances. Stevens v. Commissioner, 872 F.2d at 1505; Flynn v.
Commissioner, 93 T.C. 355, 365-366 (1989).
Petitioner has a high school education. She assisted Mr.
Womack in keeping records for his businesses, but prior to the
years in issue. She did not have access to the business books or
records for the taxable years 1989 or 1990. She was responsible
for paying routine family expenses, such as groceries, gas, and
the children's expenses, but Mr. Womack paid the larger mortgage,
utility, and insurance bills. Petitioner and Mr. Womack operated
in separate spheres financially, except that Mr. Womack provided
funds to petitioner as needed to pay household and personal
expenses. Mr. Womack paid for petitioner's breast implants and
bought her several gifts of jewelry during the years at issue.
Petitioner did not review the 1989 return and does not
remember whether she herself signed the 1990 return. This does
not excuse her from responsibility for their contents. The
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