Julian O. Von Kalinowski and Penelope J. Von Kalinowski - Page 19

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          liability in a deduction case “‘by simply turning a blind eye               
          to–-by preferring not to know of–-facts fully disclosed on a                
          return, of such a large nature as would reasonably put such                 
          spouse on notice that further inquiry would need to be made’”.              
          Price v. Commissioner, supra at 965 (quoting Levin v.                       
          Commissioner, T.C. Memo. 1987-67).  Petitioner made no inquiry as           
          to the validity of the deductions.  Her duty of inquiry thus went           
          unfulfilled.  Accordingly, we hold that petitioner possessed                
          constructive knowledge of the understatement for purposes of                
          section 6015(b)(1)(C).                                                      
          D.   The Equities–-Sec. 6015(b)(1)(D)                                       
               Even had petitioner satisfied the knowledge requirement                
          under section 6015(b)(1)(C), she would have failed to qualify for           
          relief from joint and several liability by reason of section                
          6015(b)(1)(D).  Pursuant to section 6015(b)(1)(D), a spouse                 
          seeking relief under section 6015(b)(1) must establish that it is           
          inequitable to hold him or her liable for the deficiency                    
          attributable to the understatement.  This determination must be             
          made based upon due consideration of all the facts and                      
          circumstances.  See sec. 1.6013-5(b), Income Tax Regs.  For                 
          reasons discussed below, we find that the imposition of joint and           
          several liability in this case is not inequitable.                          
               Petitioner’s principal argument regarding the equities in              
          this case is grounded in the possibility that her husband will              

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