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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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