- 34 - 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).Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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