Verna Doyel - Page 29

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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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