- 20 - illegal income does not support her contention that she had no reason to know about the understatements of tax. Instead of exculpating petitioner, the evasiveness should have caused her to question her then-husband's activities and investigate the tax returns further. See id. at 1507. Petitioner testified that Emmens "was always sticking papers in front of [her] to sign", kept extremely unusual work hours, and was very secretive about his business. Petitioner further testified that he was a "dominant person"; however, she was not prevented from examining the returns or any other documents. A reasonably prudent person in petitioner's position would have been prompted to inquire further into the joint tax liability. During the years in issue, petitioner lived a lifestyle that far exceeded the income reported on her and Emmens' joint tax returns. Their legitimate locksmith and beauty salon activities were only marginally profitable. Accordingly, we find that petitioner knew, or should have known of the substantial understatements of tax. Not Equitable To Hold Petitioner Liable To be entitled to relief as an innocent spouse, petitioner must show that it would be inequitable to hold her liable for the deficiencies in tax for the years at issue. Sec. 6013(e)(1)(D). Again assuming, arguendo, that petitioner had satisfied the knowledge requirement, she still is not entitled to innocentPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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