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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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