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these requirements. We consider only the second of these three
subparagraphs because we agree with respondent that its
requirements have not been met.
We conclude that Ms. Ford knew or had reason to know of the
1986 underpayment at the time she signed the return so as to be
precluded from receiving her requested relief under section
6015(b). Credible evidence shows that Ms. Ford was intimately
involved in the convoluted financial transactions which
transpired in 1986, that she played a crucial role in the
utilization of nominee corporations and brokerage accounts, and
that she played a crucial role in the concealment of assets
acquired in 1986, as previously discussed.
The previously discussed inconsistencies in her testimony,
piled one upon the next, also make her testimony not credible to
the Court.
______________________________
All of the parties’ arguments have been considered. We have
rejected as meritless those not discussed herein. Accordingly,
Decision will be entered
under Rule 155.
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