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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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