- 20 - in managing the finances of Contractor because his education was limited. Petitioner’s counsel agrees that petitioner was involved in the business. He argues, however, that the individual adjustments were small and that petitioner could not have actually known of every single transaction that had occurred at the time she signed the return. Under counsel’s reasoning, petitioner would be required to have a tax professional’s level of expertise for the Court to find actual knowledge under section 6015(c)(3)(C). In Cheshire v. Commissioner, 115 T.C. at 194, the Court rejected this knowledge standard. Petitioner testified that she reviewed all canceled checks for Contractor, separated the checks into business related or personal, and made notes of what each check was for. Petitioner agreed that she knew whether a given expense was business or personal. Therefore, she had knowledge of the facts as to whether an item was allowable as a deduction. See sec. 1.6015- 3(c)(2)(i)(B), Income Tax Regs. These admissions are sufficient for the Court to find that petitioner had actual knowledge of the pertinent items at the time that she signed the 1997 return. In addition, respondent asserts that petitioner has held herself out as the owner of Contractor. In support, respondent produced copies of: (1) Form 943, Employer’s Annual Tax Return for Agricultural Employees for 1995 and 1996, (2) Form 940-EZ,Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: November 10, 2007