Isaac Baranowicz and Lora D. Baran, f.k.a. Lorraine D. Baranowicz - Page 8

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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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