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The issues for decision are: (1) Whether the statute of
limitations bars the assessment and collection of the transferee
liability; (2) whether petitioner is liable as a transferee under
section 6901; and (3) whether petitioner is an innocent spouse as
to the transferee liability.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. At the
time the petition was filed, petitioner resided in Sacramento,
California. Petitioner was the wife of Alexander Locke, Jr. (the
decedent). Petitioner filed a joint 1982 Federal income tax
return with the decedent. The 1982 return reported a loss of
$63,583 from an investment in EXOCO Energy Partners (EXOCO)
partnership. The loss was in accordance with a Form K-1 filed by
EXOCO with the EXOCO return. In June 1983, respondent issued a
refund to the decedent of $23,235 claimed on the 1982 return.
The decedent died testate on June 26, 1984. On June 28,
1984, an obituary was published in the local newspaper.
Petitioner handled the estate administration herself.
On October 24, 1984, respondent sent a Notice of Beginning
of Administrative Partnership Proceeding of the EXOCO partnership
(NBAP) to "Alexander Locke, MD" at zip code 95825.
Under the will, the entire estate passed to petitioner. On
or about February 19, 1985, petitioner's certified public
accountant, C.S. Nicholas (Nicholas), filed a Form 4768,
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