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transactions, petitioner cannot qualify as an innocent spouse with
respect to petitioners' "London Options" transfers.
In regard to the final adjustments involved herein, the Six
Star Cablevision Management Corp. transactions, petitioner failed
to allege and prove that such transactions constitute "grossly
erroneous items" within the meaning of section 6013(e)(2).
Accordingly, petitioner cannot qualify for innocent spouse relief
with respect to the Six Star Cablevision Management Corp.
transactions in this case.
Petitioner had an opportunity at the August 6, 1997, hearing
to prove that she might prevail on her innocent spouse defense. She
failed to do so.
In sum, we shall deny petitioner's motion for leave to file a
motion to vacate decision.
To reflect the foregoing,
An order will be issued denying
petitioner's motion for leave to file
a motion to vacate decision.
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