- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011