Jack D. Eller - Page 9




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          spouse testified that although petitioner did not know about her            
          illegal activities, he was aware of the illegal income.  As                 
          between the two, we find petitioner’s version of the events to be           
          the more credible.  Other evidence supports our finding in this             
          regard.                                                                     
               Petitioner’s liability for each deficiency here in dispute             
          is subject to his election under section 6015(c) for each year in           
          issue.  Under the circumstances, we need not address petitioner’s           
          claim for relief under other provisions of section 6015.                    
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                        under Rule 155.                               

























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