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attribute or allocate the items giving rise to the deficiency to
H. Smith. We cannot conclude that it would be inequitable to
hold petitioner to the consequences of filing a joint return. On
consideration of the entire record, we conclude that petitioner’s
bald assertions are not reliable. We conclude further that
petitioner is not entitled to relief with respect to the
underpayment and penalties for 1987 or the deficiency and
penalties for 1992.
To reflect the foregoing,
Decision will be entered
for respondent.
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