George C. Scrimshaw and Erna C. Scrimshaw - Page 15

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         to be without any basis in fact or law.  In the instant case,                
         petitioner omits entirely any reference to her burden of proving             
         that the deductions are grossly erroneous.  Moreover, petitioner             
         failed to present facts that, even if proven, would allow her to             
         qualify for innocent spouse relief with respect to any of the                
         adjustments determined in the notice of deficiency.                          
              Petitioner voluntarily signed the March 1987 Stipulation of             
         Settled Issues with respect to the Investors Mining 77-5                     
         transaction, wherein she agreed to a basis of settlement for all the         
         notice of deficiency adjustments relating to such transactions.  She         
         testified that she read, reviewed, and subsequently signed the               
         settlement stipulation.  Thus, petitioner may not claim innocent             
         spouse status with respect to the Investors Mining Program 77-5              
         adjustments.                                                                 
              Petitioner also failed to produce evidence at the August 6,             
         1997, hearing to establish that petitioners' transactions with               
         Gardner Lohmann Limited and Amalgamated Metal Trading Limited were           
         any different from the "London Options" transfers at issue in Glass          
         v. Commissioner, 87 T.C. 1087 (1987).  Indeed, petitioner stipulated         
         that she knew that the Court and respondent treated petitioners'             
         transactions as part of the "London Options" tax shelter project.            
              "London Options" transfers are not "grossly erroneous items"            
         within the meaning of section 6013(e)(2).  Russo v. Commissioner,            
         98 T.C. at 32-33.  Because the options transactions involved herein          
         have not been shown to be different from the "London Options"                




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