Carl E. Jones and Elaine Y. Jones - Page 64

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            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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