- 24 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
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