Verna Doyel - Page 22

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               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.                                     







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