Verna Doyel - Page 34

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          Commissioner, supra.                                                        
               We also may consider whether the requesting spouse was                 
          deserted, divorced, or separated.  See Walters v. Commissioner,             
          supra.  Petitioner’s husband has not disappeared or left                    
          petitioner to “face the music” alone.  Hayman v. Commissioner,              
          992 F.2d at 1263; Von Kalinowski v. Commissioner, supra.                    
          Petitioner and Christopher remain married.  The two have not                
          separated, and petitioner has not been left by her husband to               
          deal with the tax liabilities alone.  Instead, petitioner                   
          continues to enjoy the lifestyle and financial security that are            
          largely attributable to her husband’s assets and income.                    
                    5.   Conclusion                                                   
               Petitioner was not denied access to financial records by her           
          husband or threatened with physical violence if she objected to             
          the Hoyt investment or questioned the tax returns.  There was no            
          physical or mental abuse by petitioner’s husband, and he did not            
          coerce her into investing in the Hoyt partnerships or signing the           
          tax returns.                                                                
               The understatements are not attributable to the erroneous              
          items of one individual filing the joint returns for 1982 through           
          1986, petitioner had reason to know of the understatements on               
          these returns, and it is not inequitable to hold the petitioner             
          liable for the deficiencies in tax for 1982 to 1986.  On the                
          basis of all the facts and circumstances, we conclude that                  
          petitioner is not entitled to relief pursuant to section 6015(b).           




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