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other income tax bills. Thus, the fact that the couple was not
divorced or separated appears at best to be a neutral factor in
determining the inequity question, and we afford it no negative
significance.
Taking into account all the facts and circumstances, we
conclude and hold that it would be inequitable to hold petitioner
liable for the substantial understatements in the relevant years.
For the foregoing reasons, we hold that petitioner Arlene
Epstein is an innocent spouse within the meaning of section
6013(e) as to that part of the deficiencies in income tax for the
relevant years attributable to the grossly erroneous items of her
spouse, petitioner Harvey Epstein.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011