Gerald Jacoby and Arlene Jacoby - Page 23

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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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