- 36 - In light of these facts and circumstances, we conclude, and we have found, that Nancy did not know and did not have reason to know of the substantial understatement of tax for 1981. We hold for petitioners on this issue. C. The Equities Respondent contends that it is not inequitable to hold Nancy liable for the 1981 deficiency, because of the financial benefits Nancy received from Sheldon. In particular, respondent directs our attention to the following: (1) Nancy came to the marriage with assets worth less than $50,000 and left it after Sheldon's death with assets worth more than $2.5 million, with "virtually all" of the increase having been "accumulated from Mr. Silverman's earnings." (2) Less than 3 months after receiving and depositing the $81,054.77 tax refund check for 1981, Sheldon paid a $12,840 life insurance premium from that account on his life insurance policy 8013005. When Sheldon died, Nancy received a death benefit of $489,163 from that policy. See supra table 8. (3) The claimed $1,600,000 loss deduction freed up $54,372.61 of Sheldon's 1981 income tax withholding to be applied to Sheldon's and Nancy's 1980 income tax liability,Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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