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any evidence to demonstrate that her receipt and ownership of the
Cadillac was consistent with the lifestyle to which she was
accustomed. Therefore, she has failed to establish that it would
be inequitable to hold her liable for the deficiency. We note
that pursuant to the divorce agreement Ronnie must indemnify
Linda for any underpayment of tax attributable to their 1989
return.
Accordingly, we conclude that Linda, pursuant to section
6013(e), is not entitled to be relieved of tax liability with
respect to the omitted income.
We have considered all other arguments made by petitioner
Linda and respondent and found them to be either irrelevant or
without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011