- 28 - 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).Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011