Rhonda K. Juell, a.k.a. Rhonda K. Juell-Podlak, Petitioner, and Glenn M. Evans - Page 17




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          because return preparer had signed return); Estate of Killian v.            
          Commissioner, T.C. Memo. 1987-365 (spouse took reasonable steps             
          to determine the accuracy of the return by questioning husband              
          about sham losses, who assured her that the losses were due to an           
          investment recommended by a C.P.A. who prepared the return).                
               The factors established in Price v. Commissioner, supra, as            
          to whether the electing spouse had reason to know or a duty to              
          inquire include the spouse’s level of education, the spouse’s               
          involvement in family financial affairs, the evasiveness or                 
          deceit of the culpable spouse, and any unusual or lavish                    
          expenditures inconsistent with the family’s ordinary standard of            
          living.  Erdahl v. Commissioner, supra at 591 (quoting Guth v.              
          Commissioner, supra at 444).                                                
               On the facts before us, we find that petitioner did not know           
          and did not have reason to know of the understatements on the tax           
          returns when she signed them.  Petitioner satisfied her duty of             
          inquiry by questioning her husband and receiving strong and                 
          repeated assurances from him.                                               
               All four factors discussed in Price v. Commissioner, supra,            
          weigh in favor of granting petitioner relief.  Petitioner had no            
          experience academically or practically regarding business, taxes,           
          or investments and has worked as an elementary school teacher.              
          Petitioner’s involvement in the family financial affairs was                
          limited to paying routine bills out of the joint account.  Glenn            







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