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Cir. 1990), affg. T.C. Memo. 1987-522. Factors to be considered
in determining whether a taxpayer had reason to know within the
meaning of section 6013(e)(1)(C) include: (1) The level of
education of the spouse seeking relief; (2) the alleged innocent
spouse's involvement in his or her family's financial and
business activities; (3) any substantial unexplained increase in
the family's standard of living; and (4) the culpable spouse's
evasiveness and deceit about the family's finances. Park v.
Commissioner, supra at 1293. In reaching our decision, we
consider the interaction among these factors, and different
factors may predominate in different cases. Bliss v.
Commissioner, supra at 378.
With respect to each taxable year at issue, we find that
petitioner has failed to establish that she had no reason to know
that her joint return contained a substantial understatement.
We first consider petitioner's level of education. Despite
her brief attendance at a secretarial trade school, we find that
petitioner is not formally educated beyond the high school level.
The trade school petitioner attended was not an institution of
higher learning, and we reject respondent's attempts to
characterize it as such. The secretarial training petitioner
received was practical in nature and was designed to prepare
students to enter the labor force with skills necessary to
perform secretarial duties effectively and efficiently. Such
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