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herself and her children, living well below her former standard
of living, while receiving virtually no support from
Mr. Makalintal.
We conclude that it would be inequitable to hold petitioner
liable for any income tax understatements sustained herein with
respect either to Mr. Makalintal’s sale of his ICPI stock or to
the deposits into Mr. Makalintal and petitioner’s bank accounts
and that petitioner qualifies for innocent spouse relief under
section 6013(e)(1) with respect thereto.
Mortgage Interest Expense Deduction
Petitioner has not specifically argued that she qualifies
for innocent spouse relief with respect to that portion of the
income tax understatement for 1988 relating to the erroneous
$31,335 home mortgage interest expense deduction. We conclude
that for 1988 petitioner is liable for the portion of the 1988
income tax understatement relating thereto.
Additions to Tax
Our conclusion herein that petitioner qualifies for innocent
spouse relief as to the portion of any understatements in tax for
1986, 1987, and 1988 (that are attributable to the sale of
Mr. Makalintal’s ICPI stock and to respondent’s bank deposits
analyses) also relieves petitioner from any liability for the
additions to tax relating thereto. See flush language of section
6013(e)(1).
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