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section 6015(f). Respondent disagrees.
The notice of determination stated in pertinent part:
Mrs. Beatty states that she did not review the returns
and had no idea of the amount of taxes due, if any.
Since Mrs. Beatty signed the returns without looking at
any of the figures, she had no information to make the
determination as to whether the taxes could be paid or
not. Mrs. Beatty and her attorney mentioned on numer-
ous occasions that she just signed without questioning
because she believed her husband would go to jail if
she didn’t sign. There was no thought given at that
point in time as to whether or not the taxes would be
paid. Therefore, there was no belief that the taxes
would be paid.
In support of her argument that the knowledge or reason to
know factor set forth in section 4.03(2)(a)(iii) of Revenue
Procedure 2003-61 weighs in favor of granting her relief under
section 6015(f), petitioner asserts:
Petitioner acknowledged in her responses set forth
on the Innocent Spouse Questionnaire * * * that she did
not review the returns prior to signing and therefore,
had no actual knowledge of the tax reported on the
returns, or actual knowledge that the tax reported
would not be paid. Petitioner further believed that,
based on the Beattys standard of living, they had very
little income and thus, had no reason to know that Mr.
Beatty would not pay, or be able to pay, the tax due.
* * * Petitioner did not know that Mr. Beatty had a
long-time Keno gambling problem or that he was spending
significant sums betting on Keno and repaying high
interest rate advances to loansharks. * * * Since Mr.
Beatty had been ordered by the court in his criminal
proceedings to file his missing returns, it was cer-
tainly reasonable for Petitioner to believe that Mr.
Beatty would ultimately pay the tax due.
In addition, Petitioner did not understand that
she was not required to file a return for most of the
years at issue, or that she had the option of filing
separately for those years she was required to file
(1998, 1999 and 2000). Petitioner also did not under-
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