- 18 - 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 inPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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