Dennis E. Pewitt and Kathleen M. Pewitt - Page 2

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                               Additions to Tax                                       
          Year  Deficiency  Sec. 6653(a)(1)  Sec. 6653(a)(2)  Sec. 6621(c)  Sec. 6659 
          1980   $  480        $ 24               ---             ---          ---    
          1981      931          47                1                        ---          ---
          1982      543          27                1                        ---          ---
          1983    4,357         218                1                2         $1,121  
          1984    4,889         244                1                2          1,467  

               1    50 percent of the interest due on $931 for 1981, $543 for 1982, $3,735
          for 1983, and $4,889 for 1984.                                              
               2   120 percent of the interest due on $3,735 for 1983, and $4,889 for 1984.
          Pursuant to the Tax Reform Act of 1986, sec. 1151(c)(1), Pub. L. 99-514, 100
          Stat. 2744, former sec. 6621(d) was redesignated as sec. 6621(c).           
               The deficiencies in this case arise from the disallowance of           
          Schedule E losses and investment tax credits claimed by petitioners         
          with respect to their investment in two partnerships--Media                 
          Marketers Limited Partnership (Media Marketers) and Assured                 
          Communications Limited Partnership (Assured Communications)--both           
          of which engaged in so-called jingle transactions that this Court           
          determined lacked economic substance.  See Pacific Sound Prod. Ltd.         
          Partnership v. Commissioner, T.C. Memo. 1993-253.  Petitioners              
          concede the deficiencies.  Moreover, the parties have reached a             
          settlement with respect to the additions to tax.  Petitioner                
          Kathleen M. Pewitt (Mrs. Pewitt), however, contests her liability           
          for tax, claiming that she is an innocent spouse.  Thus, the sole           
          issue to be resolved herein is whether Mrs. Pewitt is entitled to           
          tax relief as an innocent spouse pursuant to section 6013(e).  For          
          the reasons discussed, we hold she is not.                                  







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