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Further, petitioner has credibly established that she was not
involved in the trading associated with the account, nor did she
have control of any of the funds in her account. We therefore do
not find her nominal ownership significant in any aspect of this
case. Perhaps petitioner could have been more forthcoming, but
petitioner did not mislead respondent and correctly emphasized
that it was Mr. Campbell’s trading activities that generated the
claimed loss from the London straddle.
Accordingly, we find that it would be inequitable to hold
petitioner liable for the deficiency in this case.
Conclusion
Petitioner is entitled to relief under section 6015(b) since
the preponderance of the evidence indicates that she satisfied
the requirements therein.
To reflect the foregoing,
Decision will be
entered for petitioner.
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