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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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Last modified: March 27, 2008