Verna Doyel - Page 23

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               Under the Price approach, a spouse’s knowledge of the                  
          transaction underlying the deduction is not irrelevant; the more            
          a spouse knows about a transaction, the more likely it is that              
          she will know or have reason to know that the deduction arising             
          from that transaction may not be valid.  Price v. Commissioner,             
          887 F.2d at 963 n.9; see Hayman v. Commissioner, 992 F.2d at 1261           
          (citing Price).                                                             
                         a.   Education                                               
               Petitioner had a high school education.                                
                         b.   Involvement in Financial Affairs                        
               Petitioner argues that she was not involved in the family’s            
          financial affairs.  Being a homemaker, being focused on family              
          affairs, and lacking sophistication in financial affairs does not           
          relieve a taxpayer of joint and several tax liability.  Shea v.             
          Commissioner, supra at 566.  Additionally, complete deference to            
          the other spouse’s judgment concerning the couple’s financial               
          affairs, standing alone, is insufficient to establish that a                
          spouse had no “reason to know”.  Kistner v. Commissioner, supra             
          at 1525.                                                                    
               Contrary to her assertion, petitioner was involved in her              
          family’s financial affairs.  Although she may have not played a             
          “dominant” role or been the initiator, all family investment                
          decisions were made in consultation with petitioner.  Petitioner            
          and her husband had an agreement to reach a consensus about                 






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