- 22 - F.2d 561, 565-566 (6th Cir. 1986) (citations omitted), affg. in part and revg. in part T.C. Memo. 1984-310.] We believe that petitioner had reason to know of the understatements under the approaches followed by the Tax Court and the U.S. Courts of Appeals for the Sixth and Eleventh (which has adopted the Price approach) Circuits, and any disparity among them is immaterial to our disposition of this case. See Jonson v. Commissioner, supra at 116. 3. Result of the Price Approach in This Case In Price v. Commissioner, supra at 965, the Court of Appeals for the Ninth Circuit stated: A spouse has “reason to know” of the substantial understatement if a reasonably prudent taxpayer in her position at the time she signed the return could be expected to know that the return contained the substantial understatement. Factors to consider in analyzing whether the alleged innocent spouse had “reason to know” of the substantial understatement include: (1) the spouse’s level of education; (2) the spouse’s involvement in the family’s business and financial affairs; (3) the presence of expenditures that appear lavish or unusual when compared to the family’s past levels of income, standard of living, and spending patterns; and (4) the culpable spouse’s evasiveness and deceit concerning the couple’s finances. [Citations omitted.] “The interplay of these factors is dynamic, so that different factors will predominate in different cases.” Bliss v. Commissioner, 59 F.3d 374, 378 (2d Cir. 1995), affg. T.C. Memo. 1993-390. One factor may dominate the analysis and alone be reason for denying relief. Id. at 379.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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