- 23 - 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 aboutPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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