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review the tax returns before signing them. Further, all of the
account statements were handled by Thomas Dillon at Dillon
Securities. We find that the record supports petitioner's con-
tention that she lacked actual knowledge of this account.
Further, we refuse to impute constructive knowledge of this
account to petitioner. Respondent has cited a number of cases
wherein a taxpayer either had reason to know about a substantial
understatement or had sufficient knowledge such that the taxpayer
was put on notice that an understatement existed. See Hayman v.
Commissioner, 992 F.2d 1256 (2d Cir. 1993), affg. T.C. Memo.
1992-228; Stevens v. Commissioner, 872 F.2d 1499 (11th Cir.
1989), affg. T.C. Memo. 1988-63; Zimmerman v. Commissioner, T.C.
Memo. 1996-223; Kenney v. Commissioner, T.C. Memo. 1995-431.
These cases are all distinguishable from the case at bar. The
taxpayers in Hayman and Stevens, supra, were charged with
constructive knowledge of deductions listed in their tax returns.
However, in those cases, even a cursory review of the return
would have revealed the existence of substantial deductions.
Here, the understatement results from the omission of a rela-
tively small amount of investment income. Petitioner, given her
limited knowledge and lack of education, would not have noticed
anything amiss by simply reviewing the return.
Kenney v. Commissioner, supra, and Zimmerman v. Commis-
sioner, supra, involved situations where income had been omitted
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