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She regularly attended social functions with Mr. Infelise's
business associates and was present during discussions relating
to her husband's activities. Mrs. Infelise is a highly
intelligent woman and had reason to know that the joint returns
she signed understated their income. Accordingly, she is not
entitled to the relief from liability that section 6013(e)
affords.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011