Phyllis E. Campbell - Page 24

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          Further, petitioner has credibly established that she was not               
          involved in the trading associated with the account, nor did she            
          have control of any of the funds in her account.  We therefore do           
          not find her nominal ownership significant in any aspect of this            
          case.  Perhaps petitioner could have been more forthcoming, but             
          petitioner did not mislead respondent and correctly emphasized              
          that it was Mr. Campbell’s trading activities that generated the            
          claimed loss from the London straddle.                                      
               Accordingly, we find that it would be inequitable to hold              
          petitioner liable for the deficiency in this case.                          
          Conclusion                                                                  
               Petitioner is entitled to relief under section 6015(b) since           
          the preponderance of the evidence indicates that she satisfied              
          the requirements therein.                                                   
               To reflect the foregoing,                                              

                                                       Decision will be               
                                                  entered for petitioner.             
















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