Dennis E. Pewitt and Kathleen M. Pewitt - Page 9

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          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.                         













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