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unusual when compared to the family’s past levels of income,
standard of living, and spending patterns, and culpable spouse’s
evasiveness and deceit concerning couple’s finances).
Petitioner’s level of education was not made a part of the
record; however, given her limited English proficiency, her
understanding of the tax return was likely somewhat limited.
Petitioner was responsible for paying the household
expenses, and taking care of her three daughters, while Mr.
Rodriguez was responsible for preparing the couple’s tax returns.
We conclude that petitioner was at least somewhat experienced in
financial matters and in running a household. Petitioner also
had some control over financial matters because she asked the tax
preparer at Lydia’s Tax Service questions regarding certain items
relating to Mr. Rodriguez’s income. Petitioner also testified
that she tried to understand the amounts included on the return.
The record does not reflect a difference in petitioner’s
lifestyle, or the presence of expenditures that appear lavish or
unusual in comparison to the family’s past levels of income.
Petitioner’s standard of living and spending patterns reflect
those of someone attempting to raise three daughters as a single
parent on one income.
While petitioner testified that she was unaware of the
amount of the IRA distribution, we note that she has previously
been granted relief to the extent of the amount not reflected on
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