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In summary, we find that petitioner has established: (1) In
signing the joint 1983 tax return, she did not know nor did she
have reason to know of the understatement; and (2) taking into
account all the facts and circumstances, it would be inequitable
to hold petitioner liable for the resulting deficiency.
Petitioner has met all the requirements of section 6015(b), and
she is entitled to relief from joint and several tax liability as
to 1983.
To reflect the foregoing,
An appropriate decision
will be entered.
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