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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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