Joan Walters, f.k.a. Joan Gherman, and Henry Gherman - Page 62

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          supported by the record.  Although she did allow Mr. Gherman to             
          use her name in order to conduct business, there is no suggestion           
          that Ms. Walters did so with the understanding that criminal                
          activities would occur.  Indeed, as far as we know, during the              
          first 13 years of FIP's existence, no conversion of client funds            
          occurred.                                                                   
               Under the circumstances, we conclude that it would be                  
          inequitable to hold Ms. Walters liable for the deficiencies and             
          additions to tax.  Accordingly, we hold that Ms. Walters is                 
          entitled to relief under section 6013(e) as an innocent spouse.             
               To reflect the foregoing,                                              
          Decision will be entered                                                    
          under Rule 155.                                                             

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