Ann E. Bartak - Page 28

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          imputation of “reason to know” of the understatement).  Price v.            
          Commissioner, 887 F.2d at 966 ($90,000 deduction and just more              
          than $100,000 in income).  Petitioner did not satisfy her duty to           
          inquire.  Id. at 965-966; see also Mora v. Commissioner, supra at           
          289 (involving a Hoyt investment).                                          
               A reasonable person, faced with petitioner’s circumstances             
          and in petitioner’s position, would have had reason to know of              
          the understatement.  We conclude that under the Price approach              
          petitioner had reason to know of the understatements.                       
               Furthermore, for reasons similar to those stated in Doyel v.           
          Commissioner, supra, and discussed infra regarding section                  
          6015(f), it is not inequitable to hold petitioner liable for the            
          understatements contained on her joint returns.  We note that the           
          equitable factors we consider under section 6015(b)(1)(D) are the           
          same equitable factors we consider under section 6015(f).  Alt v.           
          Commissioner, 119 T.C. at 316.                                              
               The understatements are not attributable to the erroneous              
          items of one individual filing the joint returns for 1980 through           
          1986, petitioner had reason to know of the understatements on               
          these returns, and it is not inequitable to hold the petitioner             
          liable for the deficiencies in tax for 1980 to 1986.  On the                
          basis of all the facts and circumstances, we conclude that                  
          petitioner is not entitled to relief pursuant to section 6015(b).           








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