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No such untoward circumstances are present in this case. It
is clear that there was no concealment on Christopher’s part.
Christopher never hid information from petitioner, petitioner was
welcome to read all the Hoyt investment materials, Christopher
was always willing to discuss the Hoyt investment with
petitioner, petitioner never asked any questions about the Hoyt
partnership investment until she and Christopher declared
bankruptcy (after the years in issue), and petitioner did not
question the large deductions associated with the Hoyt
investment. Additionally, the evidence established that
Christopher never attempted to deceive her with respect to their
financial affairs.
As we noted supra, the purpose of section 6015 relief “is to
protect one spouse from the overreaching or dishonesty of the
other.” Purcell v. Commissioner, 826 F.2d at 475. The
understatement in tax in this case is attributable to a mistaken
belief on the part of both petitioner and Christopher as to the
legitimacy of the tax shelter deductions. Under these
circumstances, we perceive no inequity in holding both spouses to
joint and several liability. Bokum v. Commissioner, 992 F.2d at
1135; McCoy v. Commissioner, 57 T.C. 732, 735 (1972).
We have also considered other factors that are relevant to
whether it would be inequitable to hold petitioner liable. We
find that petitioner will not experience economic hardship if
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