- 5 -
(2000), affd. 282 F.3d 326 (5th Cir. 2002). Ms. Entezam, who has
a business degree, knew that large amounts of income were omitted
from the 1989 through 1992 joint tax returns. Her contentions to
the contrary were not credible. Ms. Entezam and members of her
family were involved in the operation of and record keeping
relating to the business. In addition, she signed two mortgage
loan applications reporting business income that significantly
exceeded the business income reported on the joint tax returns.
Moreover, she acknowledged that she willfully filed false joint
tax returns relating to 1989 through 1992.
Similarly, Ms. Entezam is not entitled to relief, pursuant
to section 6015(f), because it is not inequitable to hold her
liable for the deficiencies attributable to the unreported gross
receipts. See Butler v. Commissioner, 114 T.C. 276, 291-293
(2000). Ms. Entezam knew of the unreported gross receipts, did
not establish that she would suffer economic hardship if relief
were denied, significantly benefited from the unreported gross
receipts (i.e., funds deposited into a joint account afforded her
a very comfortable lifestyle), and has a legal obligation
pursuant to a divorce judgment to pay for half of the tax
liability. See Rev. Proc. 2000-15, 2000-1 C.B. 447. Thus,
respondent’s determinations are sustained.
Contentions we have not addressed are irrelevant, moot, or
meritless.
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