- 50 - 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...)Page: Previous 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 Next
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