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inquired further and/or refused to sign the return. Mrs. Sympson
has not carried her burden of showing that she neither knew nor
had reason to know of the substantial understatement on the 1987
return when she signed it.
In light of the above, we hold that Mrs. Sympson is entitled
to be relieved of liability as an innocent spouse for tax years
1982 through 1986, and that she is not so entitled for 1987.
An appropriate order and
decision will be entered.
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