Dennis E. Pewitt and Kathleen M. Pewitt - Page 8

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          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 innocent            





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