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petitioner testified that, while she had the opportunity to ask
questions during these meetings, she did not do so.
On July 12, 1988, a Form 906, Closing Agreement On Final
Determination Covering Specific Matters, relating to Progressive
Properties was executed. Pursuant to that agreement petitioner
agreed to be bound by the final decision in Finkelman v. Commis-
sioner, T.C. Memo 1989-72, affd. without published opinion 937
F.2d 612 (9th Cir. 1991). Also on July 12, 1988, another Form
906 was executed, this one relating to Oxnard Properties.
Pursuant to this Form 906, petitioner agreed to be bound by the
final decision in Finkelman v. Commissioner, supra. Amongst
other issues, Finkelman had at issue the deductibility of losses
from investment in Oxnard Properties and Progressive Properties.
Once again, petitioner testified that she signed the Form 906
simply because she was instructed by her husband's secretary to
do so. On February 16, 1989, this Court filed an opinion holding
that the losses generated by certain partnerships, including
Oxnard Properties and Progressive Properties, were disallowed.
Id.
OPINION
When a husband and wife file a joint Federal income tax
return, liability for the tax due is joint and several. Sec.
6013(d)(3). However, an "innocent spouse" can find relief under
the provisions of section 6013(e). In order to invoke the
provisions of section 6013(e), the spouse seeking relief must
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