Beverly D. Goings - Page 22

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               Having thoroughly examined the circumstances of the instant            
          case, we conclude that petitioner has failed to establish that              
          she had no reason to know of the substantial understatements of             
          tax contained on her joint returns resulting from the omission of           
          the income that Mr. Goings received from Bordelon during each of            
          the taxable years at issue.  Of the four factors discussed above,           
          only petitioner's level of education supports her argument.  The            
          weight we attribute to such factor, however, does not exceed the            
          amount of weight we attribute to any of the remaining three                 
          factors, each of which favors respondent.  Accordingly, we find             
          that, based on the entire record, petitioner had reason to know             
          of the substantial understatement of tax on her joint returns for           
          each taxable year at issue resulting from the omission of the               
          income that Mr. Goings received from Bordelon.                              
               Section 6013(e)(1)(D)                                                  
               The next matter we consider is whether it would be                     
          inequitable to hold petitioner liable for the deficiencies in tax           
          attributable to the omitted kickback income.  See sec.                      
          6013(e)(1)(D).  In answering this question, we take into account            
          all of the facts and circumstances.  Id.; sec. 1.6013-5(b),                 
          Income Tax Regs.  A factor to be considered is whether the spouse           
          seeking relief significantly benefited, either directly or                  
          indirectly, from the omitted income.  Buchine v. Commissioner, 20           
          F.3d 173, 181 (5th Cir. 1994), affg. T.C. Memo. 1992-36; sec.               
          1.6013-5(b), Income Tax Regs.  Normal support, which is to be               




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