Shirley H. Startzman, Petitioner, and Larry G. Easler, Intervenor - Page 8

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               In the instant case, petitioner knew or had reason to know             
          of the omitted item giving rise to the deficiency.  A requesting            
          spouse has a duty of inquiry.  Butler v. Commissioner, 114 T.C.             
          276, 284 (2000).  A requesting spouse has reason to know of an              
          understatement if a “reasonably prudent person with knowledge of            
          the facts possessed by the person claiming * * * [relief] should            
          have been alerted to the possibility of a substantial                       
          understatement.”  Flynn v. Commissioner, 93 T.C. 355, 365 (1989).           
          There is no question that petitioner was aware intervenor was               
          employed by Greenwood Mills throughout 1997.  The top line of               
          page two of the Easlers’ 1997 tax return shows an adjusted gross            
          income of $12,030.78.  A few inches above where petitioner signed           
          her name on page two, line 29a shows total tax withholdings from            
          Forms W-2 of just $444.24.  Such circumstances should have                  
          alerted a reasonably prudent person that there was an                       
          understatement of tax.  Section 6015 relief was not intended for            
          spouses who simply did not look at the amount of income reported            
          on the return, unless it is clearly established that the spouse             
          was forced under duress to sign the return without looking at it.           
          Frederick v. Commissioner, T.C. Memo. 1981-602.  The record in              
          the instant case does not support a conclusion that petitioner              
          was forced to sign the return under duress.  Even though                    
          petitioner did not have a college degree or any business                    







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