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pay the tax liabilities in question. Given this fact, it is
highly unlikely that Mr. Dillon will be able to make good on his
promise to reimburse petitioner if she is required to pay the tax
liability, penalties, and interest related to the 1982
deficiency.
Accordingly, we find, based on the evidence, that it would
be inequitable to hold petitioner liable for the 1982 deficiency.
We therefore conclude that she is entitled to innocent spouse
relief with respect to the deficiency and additions to tax which
resulted from Thomas Dillon's failure to report, in the Dillons'
1982 Federal income tax return, the investment income earned from
the Murphy Favre account.
To reflect the foregoing,
An appropriate decision
will be entered.
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Last modified: May 25, 2011