Eugene McClelland and Ione McClelland - Page 17

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               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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