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whether the failure to report the correct tax liability on the
joint return results from concealment, overreaching, or any other
wrongdoing on the part of the other spouse. Alt v. Commissioner,
supra at 314; Jonson v. Commissioner, 118 T.C. at 119.
No such untoward circumstances are present in this case.
There was no concealment on Ms. Becherer’s part. Ms. Becherer
never hid her employment from petitioner, and in fact petitioner
helped Ms. Becherer perform some of her employment duties.
Petitioner had the opportunity to review the 1996 Federal income
tax return before it was filed.
A purpose of section 6015 relief “is to protect one spouse
from the overreaching or dishonesty of the other.” Purcell v.
Commissioner, 826 F.2d 470, 475 (6th Cir. 1987), affg. 86 T.C.
228 (1986). The understatement of tax in this case is
attributable to an omission of income from the employment
activities of petitioner’s former spouse. Petitioner had
knowledge of Ms. Becherer’s employment activities. Under these
circumstances, we perceive no inequity in holding petitioner and
Ms. Becherer to joint and several liability. Bokum v.
Commissioner, 992 F.2d 1132, 1135 (11th Cir. 1993), affg. 94 T.C.
126 (1990); McCoy v. Commissioner, 57 T.C. 732, 735 (1972).
We conclude that holding petitioner liable for the
deficiencies in tax for 1996 is not inequitable under section
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