-15-
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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