- 11 - petitioner argues that, because her area of expertise is limited to the study of fabrics and clothing, rather than business and accounting, we should attribute little if any weight to her academic degrees and status as a professor. We reject petitioner's efforts to attenuate her academic accomplishments by pointing to the nature of her expertise. Based on the record in the instant case, we are satisfied that a reasonably prudent taxpayer with petitioner's education would have had the ability to understand that there was a substantial understatement on each of the joint returns. While it is not uncommon for courts to conclude that highly educated intelligent taxpayers are entitled to innocent spouse relief, cf. Resser v. Commissioner, 74 F.2d 1528 (7th Cir. 1996); Friedman v. Commissioner, 53 F.3d 523 (2d Cir. 1995) ; Foley v. Commissioner, T.C. Memo. 1995-16; Robertson v. Commissioner, T.C. Memo. 1992-32, the facts of the instant case do not support a similar conclusion. We do not believe that it was necessary for petitioner to have possessed specialized knowledge and education in order for her to have had reason to know income was being omitted from her joint returns. This case does not involve transactions the nature of which would require special understanding or knowledge to appreciate. Rather, it involves the omission of embezzlement income. Cf. Resser v. Commissioner, supra. That Mr. Peterson's law practice may have been complex in nature, and despite petitioner's professed lack of knowledge with respect to the operation of that practice, isPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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