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Because petitioner relied solely on Mr. Pierce’s
explanations, she may not have completely understood the legal
consequences of her signing documents creating DDC and MCU,
lending money between these business entities, and transferring
property between herself and the business entities. However, the
ultimate object of these transactions was to shield assets from
creditors, which ultimately included the Internal Revenue
Service. The granting of relief to petitioner in these
circumstances would permit the Pierces to shield themselves from
Federal tax liabilities by using section 6015.
Accordingly, we hold that petitioner has not satisfied the
requirements under section 6015(b)(1)(C) or (D) and is not
entitled to relief from joint and several liability for the tax
years at issue.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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