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On the evidence before us, we conclude Lora did not have
actual knowledge of the underlying circumstances resulting in the
disallowance of the deductions related to the equipment leasing
partnership investments. Isaac sought out these equipment
leasing partnership investments. Lora was a homemaker, mother,
and part-time student of interior decorating. Lora was only
generally familiar with the existence of the investments in the
equipment leasing partnerships. Isaac invested in the equipment
leasing partnerships in his own name, and Isaac, independently of
Lora, used the information relating to those investments in
preparation of the joint income tax returns. Lora relied on
Isaac’s professional experience as a C.P.A. in signing the joint
income tax returns. Based on all the facts before us, we agree
with Lora and respondent that Lora did not have actual knowledge
of the underlying equipment leasing partnership transactions
giving rise to the stipulated deficiencies, and, therefore, that
Lora is entitled to relief from joint liability under section
6015(c) for the years in issue.
Herein, we need not address arguments regarding whether Lora
is entitled to relief under section 6015(b). Other arguments
made by petitioners that are not specifically addressed have been
considered and rejected.
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Last modified: May 25, 2011