Beverly D. Goings - Page 18

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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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