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tion before the Court, that at the time she signed each of the
respective joint returns for the years at issue (1) she did not
know that each such return showed tax due, and (2) therefore she
did not know at that time that Mr. Beatty would not pay such tax.
On the record before us, we find Washington v. Commissioner,
supra, to be materially distinguishable from the instant case and
petitioner’s reliance on that case to be misplaced.
We address now whether petitioner has carried her burden of
establishing that the knowledge or reason to know factor weighs
in favor of granting relief. In support of her position for
relief under section 6015(f), petitioner chose to present her
case to the IRS and to the Court by claiming that she did not
know that there was a tax shown due in each of the respective
joint returns for the years at issue. Petitioner must bear the
consequences of that choice. Assuming arguendo that we were to
accept petitioner’s contention that she did not know that each of
the joint returns for the years at issue showed tax due, on the
record before us, we find that, by signing each such return,
petitioner is charged with constructive knowledge of, inter alia,
the tax shown due therein. See Park v. Commissioner, 25 F.3d
1289, 1299 (5th Cir. 1994), affg. T.C. Memo. 1993-252; see also
Hayman v. Commissioner, 992 F.2d 1256, 1262 (2d Cir. 1993), affg.
T.C. Memo. 1992-228. We further find that petitioner should have
inquired about whether the tax shown due in each of the joint
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