- 29 - she would bear the entire burden of the tax liabilities resulting from the understatement attributable to the Magnum deductions. Considering that petitioner did not receive significant benefit from the understatements and the future probable hardship that would be imposed if relief were denied, we find that it would be inequitable to hold petitioner liable for the resulting deficiencies. Therefore, petitioner has satisfied section 6013(e)(1)(D). In summary, we find that petitioner has established (1) that she did not know and did not have reason to know that there was a substantial understatement relating to the Magnum deductions and (2) that it is inequitable to hold her liable for the resulting deficiencies. Taking into account the parties' stipulations, supra, we, therefore, hold that petitioner has met all of the requirements of section 6013(e), and she is entitled to relief as an innocent spouse for any income tax liability attributable to the understatements for the years in issue arising from the Magnum investment. To reflect the foregoing, Decisions will be entered under Rule 155.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
Last modified: May 25, 2011