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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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