Julian O. Von Kalinowski and Penelope J. Von Kalinowski - Page 17

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          standard of living or spending habits would have alerted her to             
          the fact that her and her husband’s tax obligations were not                
          being accurately reported.                                                  
               2.   Facts Supporting a Finding That Petitioner Possessed              
                    Constructive Knowledge of Understatement                          
               While certain considerations in this case support a finding            
          that petitioner lacked constructive knowledge of the                        
          understatement, others support a contrary conclusion.  Petitioner           
          is not unsophisticated in financial matters.  She is an educated            
          woman, and her studies included a course in financial accounting.           
          Petitioner worked for a number of years prior to her marriage,              
          presumably receiving paychecks, paying bills, and filing income             
          tax returns.  Furthermore, during the tax years at issue,                   
          petitioner ran her own sole proprietorship.  Although not a large           
          enterprise, petitioner’s experience was certainly sufficient to             
          provide her an understanding of what it meant for a business to             
          incur a profit or a loss.  With respect to her business,                    
          petitioner prepared the tax information necessary to be included            
          on the tax return.                                                          
               3.   Duty of Inquiry                                                   
               The facts supporting a conclusion that petitioner possessed            
          constructive knowledge of the understatement become increasingly            
          persuasive in light of the information that was included on the             
          tax returns which petitioner executed.  Although petitioner did             
          not review the returns prior to signing them, she is charged with           

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