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spending. This factor, however, is not determinative. Id. at
118.
The losses helped to reduce petitioner and her husband’s
reported tax liabilities for 1984 through 1986 to a total of
$394. Such deductions, which shelter such a large percentage of
the income reported on the returns, support a finding that
petitioner had reason to know of the understatement. Id.
Section 6015 relief “was not designed to protect willful
blindness or to encourage the deliberate cultivation of
ignorance.” Friedman v. Commissioner, 53 F.3d 523, 525 (2d Cir.
1995), affg. in part and revg. and remanding in part T.C. Memo.
1993-549. “Extravagant tax savings may alert even a financially
unsophisticated spouse to the possible improprieties of a tax
scheme.” Id.
d. Other Spouse’s Evasiveness and Deceit
Where one spouse is “cunning and systematic” in concealing
the understatement of taxes, the other spouse may plausibly claim
ignorance notwithstanding some educational attainments or some
involvement in family financial affairs that are distinct from
the understatement of taxes. Bliss v. Commissioner, supra at
379. Disclosure by the other spouse, however, is probative in
determining that relief is inappropriate. Id.; see also Hayman
v. Commissioner, supra at 1262, 1263 (lack of deceit by other
spouse important factor in denying relief).
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