Verna Doyel - Page 25

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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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