-64-
Service. Although Mrs. Jones testified that she had never been a
professional decorator, she listed "Decorator" as her occupation
on each return for the years at issue. Therefore, in considering
her level of education, we find that Mrs. Jones had a practical
education in business.
Furthermore, petitioners concede that petitioner did not
prevent Mrs. Jones from examining the returns, dominate or abuse
her, or otherwise coerce her into signing the returns. Cf.
Kistner v. Commissioner, supra at 1527 (a reasonably prudent
taxpayer living an affluent life for many years, fearful of
physical violence, and uninvolved in the financial affairs of the
business, at the time of signing the return could not be expected
to know that the tax liability stated was erroneous or that
further investigation was necessary).
We think that a reasonably prudent person would have
inquired how she could receive distributions of valuable real
estate free of encumbrances without reporting them as income.
Mrs. Jones had reason to know that the tax liability stated was
erroneous or that further investigation was warranted.
Not Equitable To Hold Mrs. Jones Liable
To be entitled to relief as an innocent spouse, Mrs. Jones
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).
In deciding whether it is inequitable to hold a spouse
liable for a deficiency, we consider whether the purported
innocent spouse significantly benefited beyond normal support,
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