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PIETROMONACO v. C.I.R.

No. 92-70101.

3 F.3d 1342 (1993)

Emilia R. PIETROMONACO, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided September 2, 1993.

Attorney(s) appearing for the Case

Bruce I. Hochman and Dennis L. Perez, Hochman, Salkin & Deroy, Beverly Hills, CA, for petitioner-appellant.

Reginia S. Moriarty and Gary R. Allen, U.S. Dept. of Justice, Tax Div., Washington, DC, for respondent-appellee.

Before: NOONAN, FERNANDEZ, and KLEINFELD, Circuit Judges.

FERNANDEZ, Circuit Judge:

Emilia Pietromonaco ("Emilia") appeals from the Tax Court's decision that she was ineligible for relief from tax liability under the "innocent spouse" provision, 26 U.S.C. § 6013(e) (1990).1 Emilia contends that she was "innocent" within the meaning of the provision and that she should have been shielded from liability arising out of a tax deficiency. That deficiency was the result of income omissions in...

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