- 23 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011