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expenses. Given the paucity of information in the record, we
view this factor as neutral.
C. Knowledge or Reason To Know
A spouse’s knowledge, or reason to know, of the income from
which she seeks relief is a factor in determining whether the
spouse should be granted equitable relief. In evaluating whether
a spouse had reason to know of an item of community income, Rev.
Proc. 2003-61, supra, provides that we may consider the spouse’s
level of education, any deceit or evasiveness, the spouse’s
degree of involvement in the activity generating the tax
liability, her involvement in business and household financial
matters, and her business or financial expertise.
Petitioner was undeniably an unsophisticated spouse with
respect to business and household financial matters. Petitioner
did not speak English when she immigrated to the United States in
1994 and had no prior experience with financial matters or with
running a household. Further, it is undeniable that Mr. Bennett
exercised complete control over their financial matters. Mr.
Bennett filed income tax returns and was responsible for
virtually all matters relating to their household finances.
Petitioner often signed documents at the request of Mr. Bennett
without knowing or understanding what she was signing. Mr.
Bennett forbade petitioner to open mail that arrived at their
home, to review bank statements from their joint bank accounts,
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