Donald J. Barnes and Beverly A. Edwards, f.k.a. Beverly A. Barnes - Page 47

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                    (f) Requesting spouse’s legal obligation.  The                    
               requesting spouse has a legal obligation pursuant to a                 
               divorce decree or agreement to pay the liability.                      
               As previously discussed in detail in this opinion, we have             
          found that both petitioner and Mr. Barnes were investors in the             
          partnership, and we have accordingly found that the deficiencies            
          are attributable equally to petitioner and Mr. Barnes.  In                  
          reviewing respondent’s denial of section 6015(f) relief with                
          respect to the portions of the deficiencies attributable to                 
          petitioner, we find petitioner’s personal involvement as an                 
          investor to be a significant factor.  Another significant factor            
          weighing against relief is that petitioner had reason to know of            
          the understatements, as discussed above in connection with the              
          application of section 6015(b).                                             
               There is no evidence that petitioner was abused by Mr.                 
          Barnes, or that petitioner was to any degree coerced into                   
          becoming an investor--even if petitioner went along with the                
          investment in order to avoid conflict with Mr. Barnes or his                
          family, she nevertheless became an investor voluntarily.                    
          Petitioner’s arguments to the contrary are not supported by the             
          record and are even contradicted by petitioner’s own testimony.             
          Finally, because petitioner has not shown that she would be                 
          unable to pay her reasonable basic living expenses, especially in           
          light of the substantial continuing income that she and Mr.                 
          Edwards receive, petitioner has not shown that she would suffer             






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