Helen M. Korchak - Page 50

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          entities to which those respective claimed credits were attribut-           
          able.                                                                       
               It is also significant that an examination of the education            
          factor, the involvement in financial affairs factor, the evasive-           
          ness and deceit factor, and the lavish or unusual expenditures              
          factor further supports a finding that a reasonably prudent                 
          taxpayer under petitioner’s circumstances at the time of signing            
          the 1982 joint tax return could not have been expected to know              
          that the tax liability stated in that return was erroneous.                 
               With respect to the education factor, there is no question             
          that petitioner is highly educated.  However, at the time of the            
          trial, petitioner did not have any education or work experience             
          in tax, financial, or accounting matters.  We find nothing in the           
          record regarding petitioner’s education and experiences that                
          would, or should, have alerted her to the understatement in the             
          1982 joint tax return.                                                      
               With respect to the involvement in financial affairs factor,           
          respondent concedes in the face of the instant record “that the             
          record supports petitioner’s contention that she had little                 
          involvement in her family’s financial affairs.”24                           


               24We have found:  (1) Based on their respective personal and           
          business backgrounds and experiences, petitioner and Mr. Korchak            
          believed throughout their marriage that managing their family’s             
          finances should be Mr. Korchak’s responsibility and that Mr.                
          Korchak was better suited than petitioner to do so; (2) Mr.                 
          Korchak assumed the responsibility of managing their family’s               
          finances, and petitioner relied upon him to do so; (3) as part of           
                                                             (continued...)           




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