- 13 -
112 T.C. 19, 23 (1999); Mailman v. Commissioner, 91 T.C. 1079,
1082-1084 (1988).
In the case of a liability that was reported but not paid,
the fact that the requesting spouse did not know and had no
reason to know that the liability would not be paid is a factor
weighing in favor of granting relief. Rev. Proc. 2000-15, sec.
4.03(1)(d), 2000-1 C.B. at 449. By contrast, the fact that the
requesting spouse knew or had reason to know that the reported
liability would be unpaid is an extremely strong factor weighing
against relief. Rev. Proc. 2000-15, sec. 4.03(2)(b), 2000-1 C.B.
at 449. Respondent contends that petitioner did not prove that
she did not know or did not have reason to know that the unpaid
1994 tax liability would not be paid at the time the return was
filed.
The taxpayer has a "duty of inquiry" to determine the amount
of her tax liabilities. See Price v. Commissioner, 887 F.2d 959,
965 (9th Cir. 1989), revg. an Oral Opinion of this Court; Butler
v. Commissioner, 114 T.C. 276, 284 (2000). A taxpayer is not
relieved of her duty of inquiry because she relied on her husband
to take care of the returns. See Hayman v. Commissioner, 992
F.2d 1256, 1262 (2d Cir. 1993), affg. T.C. Memo. 1992-228. A
taxpayer can not obtain the benefits of relief from joint and
several liability simply because she turned a "blind eye" by
signing a blank return and then failed to make further inquiry
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