Sherry P. Aude - Page 29

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          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.                                    












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