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equitable relief under section 6015(f). Finally, we address
whether petitioner is liable for any additions to tax or
penalties for the years in issue.
I. Retirement Account Distributions
A. Background
In 1990, lump-sum distributions were made from various
pension, profit sharing, and retirement accounts bearing the name
of either petitioner or Mr. Rowe. The taxable amount distributed
from the accounts in Mr. Rowe’s name totaled $112,979. The
taxable amount distributed from an individual retirement account
(IRA) in petitioner’s name totaled $3,426. These amounts were
not reported on petitioners’ 1990 Federal income tax return.
Respondent concedes that petitioner is entitled to be relieved
from joint liabilities attributable to the amount distributed
from Mr. Rowe’s accounts.
B. Discussion
1. Allocation of Item
Petitioner argues that the distributions from the IRA in her
name are allocable to Mr. Rowe because he concealed the account
from petitioner and she was not aware of the account or the
distributions until after she signed the return for the year in
issue. Respondent contends that the distributions from the IRA
are allocable to petitioner because the account was in her name
and she received the distributions.
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