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testimony at trial all indicate that petitioner participated
meaningfully.
We agree with respondent. In Huynh, petitioner signed all
documents, participated in pretrial preparations and settlement
negotiations, and testified at trial.
Petitioner may have signed some documents under the
direction of Hong. Petitioner, however, reads English. She
prepared her and Hong’s joint Federal income tax returns. She
was present at meetings with respondent’s Appeals Office, as well
as at pretrial meetings with respondent’s counsel, and at trial.
In Huynh, petitioner was not formally represented by
counsel. Hong, however, has a law degree, and petitioner has
introduced no evidence that Hong did not allow her the
opportunity to raise therein her innocent spouse claim.
We conclude that petitioner meaningfully participated in
Huynh and that petitioner therefore is barred under section
6015(g)(2) from obtaining any relief from joint liability for
1996 and 1997.
For the reasons stated, we shall sustain respondent’s
determination to deny relief from joint liability.
To reflect the foregoing,
Decision will be entered
for respondent.
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