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taxpayer's situation in Wiksell. We find that petitioner did not
have reason to know about the understatement. Petitioner did not
have substantial cash on hand, did not report small sums, and did
not have unusual expenditures for the years at issue. In our
case, the evidence does not show that petitioner knew or had
reason to know that something was awry on the joint returns. As
a result, we find that the physical abuse by Mr. Aude is one of
the factors for us to consider in explaining her deference to Mr.
Aude. See Makalintal v. Commissioner, T.C. Memo. 1996-9.
In Estate of Brown v. Commissioner, T.C. Memo. 1988-297,
spousal abuse was considered as a factor. In that case,
taxpayer's husband repeatedly physically abused his wife. Id.
When he needed taxpayer's signature on a document, he would
merely present the document and did not give her an opportunity
to read it. Id. Taxpayer "always complied with his demands, for
fear that she would be beaten if she refused." Id. In that
case, the following was emphasized: That taxpayer's husband was
primarily responsible for the operations of the business; that he
told his wife almost nothing about the company's affairs; and
furthermore that she was forced to sign documents in fear that
she would be beaten if she did not comply with her husband's
demands. Id. Brown concluded that the taxpayer did not know or
have reason to know of the income omitted from the joint returns.
Id.
While petitioner was not coerced or physically threatened
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