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not pay the liabilities reported on the returns.
Petitioner contended at trial that she did not know and had
no reason to know that the liabilities reported on the joint
returns for taxable years 1998, 1999, and 2000, would not be paid
because she did not know that the returns showed any taxes due
when she signed them. In support of her contention, petitioner
testified that she did not prepare the returns in issue, never
reviewed or looked through the returns when she signed them, and
never asked Mr. Barrera about paying the reported liabilities.
For purposes of our analysis herein, we are willing to
accept petitioner’s contention that she did not see the balance
due amounts reported on the 1998, 1999, and 2000 joint returns
and thus did not have actual knowledge that Mr. Barrera would not
pay those liabilities when she signed the respective returns.
Nonetheless, petitioner must still establish that she had no
reason to know that Mr. Barrera would not pay the reported
liabilities at the times she signed the joint returns.
In order to satisfy the reason to know factor, a taxpayer
must establish that it was reasonable for the taxpayer to believe
that his or her spouse would pay the reported liability at the
time the taxpayer signed the return. See, e.g., Hopkins v.
Commissioner, 121 T.C. 73, 88-89 (2003); Knorr v. Commissioner,
T.C. Memo. 2004-212; Morello v. Commissioner, T.C. Memo.
2004-181; Keitz v. Commissioner, T.C. Memo. 2004-74; Ogonoski v.
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