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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withdrawn by Mr.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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