- 9 - spouse relief." Price v. Commissioner, 887 F.2d 959, 964 (9th Cir. 1989). Further, there is no apparent difference between petitioner's and Mr. Pewitt's knowledge of the investment. Suffice it to say, neither petitioner nor Mr. Pewitt fully grasped the nature and risks of the investments. See McCoy v. Commissioner, 57 T.C. 732 (1972). But they both attended a meeting with Mr. Colwill where he explained the potential tax benefits and risks of the investments. Moreover, petitioner and Mr. Pewitt discussed the tax returns involved and the refunds they were to receive. Additionally, we do not believe it would be inequitable to hold petitioner liable because she shared with her husband the tax benefits resulting from the claimed deductions and credits. To conclude, we hold that petitioner is not entitled to innocent spouse relief for any of the years under consideration. To reflect the foregoing and the parties' settlement with respect to the additions to tax, An appropriate Decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011