- 17 - 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 tookPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011