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believe the unpaid tax reported on the returns would be paid.
Respondent contends that petitioner’s reliance on intervenor’s
assurances that he would pay all taxes due was unreasonable
because intervenor had underpaid his estimated taxes and the
Murrays habitually owed money that they could not pay. We
disagree. Intervenor intentionally misled petitioner into
thinking he was fulfilling their tax obligations.
Petitioner had a high school education and stayed home to
raise their children during most of the years she was married to
intervenor. Respondent apparently did not consider petitioner’s
education or lack of involvement in family finances, even though
(1) all facts and circumstances are to be considered in applying
section 6015(f), sec. 6015(f)(1); and (2) a taxpayer’s level of
education and lack of involvement in family finances are well-
established considerations in determining what a taxpayer knows
or had reason to know, Bliss v. Commissioner, 59 F.3d 374, 378
(2d Cir. 1995), affg. T.C. Memo. 1993-390; Guth v. Commissioner,
897 F.2d 441, 444 (9th Cir. 1990), affg. T.C. Memo. 1987-522.
We conclude that the record shows that at the times the
returns were filed petitioner expected intervenor to pay the
Murrays’ taxes after their returns were filed.
d. The Lien on the Murrays’ House and the Bankruptcy
Respondent contends that petitioner knew or had reason to
know intervenor would not pay his taxes because respondent took
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