- 8 - through 1984. The evidence establishes that petitioner was a limited partner in both Media Marketers and Assured Communications. She signed documents authorizing the investments, and Forms K-1 were issued naming both petitioner and her husband as partners in the limited partnerships. Petitioner attended a meeting in which she was informed about the tax risks and rewards of making an investment in the limited partnerships, and she acquiesced in becoming a partner with her husband. See Hayman v. Commissioner, 992 F.2d 1256 (2d Cir. 1993), affg. T.C. Memo. 1992-228; Feldman v. Commissioner, 20 F.3d 1128 (11th Cir. 1994), affg. T.C. Memo. 1993- 17. Although petitioner may not have understood the technical tax nuances involved in petitioners' investment in the two limited partnerships, we believe she knew (1) that such investments would enable petitioners to claim substantial deductions and tax credits that would result in the reduction of the amount of taxes petitioners otherwise would owe, and (2) that the Internal Revenue Service might disallow these deductions and tax credits upon audit of petitioners' returns. Petitioner asserts she is an "ignorant spouse". But as the United States Court of Appeals for the Ninth Circuit (where an appeal of this case would lie) has said: "Of itself, ignorance of the attendant legal or tax consequences of an item which gives rise to a deficiency is no defense for one seeking to obtain innocentPage: Previous 1 2 3 4 5 6 7 8 9 Next
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