Carolyn A. Glenn - Page 17

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         is a factor in favor of granting relief.  Rev. Proc. 2003-61,                
         sec. 4.03(2)(a)(iii)(B).  By contrast, the fact that the                     
         requesting spouse knew or had reason to know of the item giving              
         rise to the deficiency is a factor weighing against relief.  Id.             
              Petitioner contends that she did not know and had no reason             
         to know of the distribution from Mr. Glenn’s section 401(k) plan             
         which gave rise to:  (1) The deficiency resulting from the 10-               
         percent early withdrawal additional tax, and (2) the accuracy-               
         related penalty imposed under section 6662(a).  Petitioner                   
         testified:  (1) It was Mr. Glenn’s sole responsibility to                    
         maintain their household finances; (2) she had no knowledge or               
         control of their household finances during tax year 2001 or prior            
         years; (3) she had no knowledge of the existence of Mr. Glenn’s              
         section 401(k) plan maintained by his employer, Kronos, Inc.,                
         through T. Rowe Price, nor did she know that the proceeds were               
         withdrawn by Mr. Glenn during tax year 2001 and placed into their            
         joint accounts with Harris Trust & Savings Bank; and (4) she had             
         no control of the proceeds which were placed into the joint                  
         accounts with Harris Trust & Savings Bank.                                   
              However, petitioner voluntarily signed the 2001 joint return            
         and admitted that she did not review the joint return before                 
         filing.  The distribution from Mr. Glenn’s section 401(k) plan               
         maintained by his employer, Kronos, Inc., through T. Rowe Price,             
         was reported on petitioner and Mr. Glenn’s 2001 joint return.                






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