- 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...)
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