Sybil M. Smith - Page 12




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          Without any elaboration on the subject matter of petitioner’s               
          testimony, and based on her own words rather than her counsel’s,            
          we are not satisfied that her conclusions are based on facts.               
               Petitioner testified in a similar manner that all income               
          other than her salary reported on the 1992 return was                       
          attributable to her husband and that income taxes were withheld             
          from her earnings during 1992.  The stipulated facts, however,              
          contradict petitioner’s recollection of income taxes being                  
          withheld.  According to the stipulation, no payments on the 1992            
          liabilities were made before 1998.  Any withholding from                    
          petitioner’s wages would have been reflected as of April 1993.              
          In the absence of either the tax return or the notice of                    
          deficiency for 1992, we cannot tell whether the deficiency                  
          resulted from unreported income, from petitioner’s or H. Smith’s            
          income, or from disallowed deductions that were apparent on the             
          face of the return.                                                         
               Petitioner claims that she is entitled to relief under                 
          section 6015(b), (c), or (f) for 1992 and under section 6015(f)             
          for 1987.  She concedes that, with respect to liabilities                   
          reported on the return but not paid, relief is available only               
          under section 6015(f).  Petitioner relies on the above testimony            
          to establish that the understatement of tax for 1992 was                    
          attributable to H. Smith and that she had no reason to know of              
          the deficiency.  Petitioner argues that it would be inequitable             






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