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training was not otherwise designed to advance the level of
petitioner's formal education.
Respondent contends that petitioner's 20-plus years as a
secretary in LSDT's legal department serves as an adequate
substitute for petitioner's lack of formal education beyond the
high school level. We disagree, and, in light of the entire
record, coupled with our observations of petitioner at trial,
conclude that this factor narrowly favors petitioner.
We next consider petitioner's involvement in her family's
financial and business affairs. Perfect knowledge of one's
family's financial affairs is not required to satisfy the reason
to know standard. Shea v. Commissioner, 780 F.2d 561, 567 (6th
Cir. 1986), affg. in part, revg. in part and remanding T.C. Memo
1984-310; Sanders v. Commissioner, 509 F.2d at 168. We conclude
that petitioner has failed to establish that her involvement in
her family's affairs was insufficient to put a reasonable person
in her position on notice that the income reported in the returns
at issue was erroneous or that further inquiry was warranted.
While petitioner maintains that Mr. Goings had exclusive
control of her family's financial affairs, this contention is
contradicted by petitioner's own testimony. Petitioner testified
that she, not Mr. Goings, managed her family's joint checking
account. In 1985 and 1986, $62,767 and $48,000, respectively, of
the funds Bordelon paid Mr. Goings were deposited into the joint
account managed by petitioner. Such deposits are significant in
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