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Gerald invested in tax shelters in the taxable years 1975
through 1980, and the tax savings derived from the tax shelter
investments went into his businesses. Gerald left petitioner
with the deficiencies for the taxable years 1975 through 1977,
which she paid. Respondent now intends to collect from
petitioner the deficiencies for the taxable years 1978 through
1980. In short, Gerald made the investments, appropriated the
benefits, and left petitioner with the tab. We conclude that it
would be inequitable to hold petitioner liable for the
deficiencies.
We hold that petitioner qualifies as an innocent spouse.
To reflect the foregoing,
An appropriate
decision will be entered
in accordance with the
stipulation of settlement
as to petitioner Gerald
Jacoby, and decision will
be entered for petitioner
Arlene Jacoby.
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