- 22 - 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 bePage: 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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