- 17 -
More importantly, we are convinced that Mr. McClelland was
responsible for Red Wing’s claiming an improper interest paid
deduction. It is well settled that a purpose of section 6015
relief “is to protect one spouse from the overreaching or
dishonesty of the other.” Purcell v. Commissioner, 826 F.2d 470,
475 (6th Cir. 1987), affg. 86 T.C. 228 (1986).
We therefore conclude, by a preponderance of the evidence,
that it would be inequitable to hold Ms. McClelland liable for
the 1997 deficiency.
D. Conclusion
Ms. McClelland is entitled to innocent spouse relief under
section 6015(b), since the preponderance of the evidence
indicates that she satisfied the requirements therein.
We need not rule on Ms. McClelland’s alternative claim for
innocent spouse relief under section 6015(f) because of our
holding that she qualifies for relief under section 6015(b).
To reflect the foregoing and give effect to the parties’
stipulation of settlement,
Appropriate decisions will
be entered.
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