What are the factors used to determine whether a spouse has reason to know of a substantial understatement on a spouse's income statement?

Price v. Commissioner, 887 F.2d 959, 961-62 (9th Cir.1989) (footnotes omitted). Both parties concede that the first two factors were satisfied. Only the third and fourth factors are at issue.

1. Lack of Knowledge, 26 U.S.C. Sec. 6013(e)(1)(C)

"A spouse has 'reason to know' of the substantial understatement if a reasonably prudent taxpayer in her position at the time she signed the return could be expected to know that the return contained the substantial understatement." Price, 887 F.2d at 965 (emphasis added); Sanders v. United States, 509 F.2d 162, 166-67 (5th Cir.1975) (remedial purpose of statute calls for reasonable person standard). The standard is objective because we look at the reasonably prudent taxpayer, but this objective standard is not an abstraction. It is the reasonably prudent taxpayer in the particular circumstances in which the taxpayer before us was placed. We have held that several factors should be considered in determining whether a spouse has "reason to know" including: "(1) the spouse's level of education; (2) the spouse's involvement in the family's business and financial affairs; (3) the presence of expenditures that appear lavish or unusual when compared to the family's past levels of income, standard of living, and spending patterns; and (4) the culpable spouse's evasiveness and deceit concerning the couple's finances." Price, 887 F.2d at 965; Stevens v. Commissioner, 872 F.2d 1499, 1505 (11th Cir.1989).