Sam F. Ford and Ingrid D. Ford - Page 30

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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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