Innocent spouseries are all balancing acts. Mostly they’re the daily grist of separating credibility from self-service (but isn’t all testimony self-serving? Doesn’t even self-denunciation secure some intangible spiritual benefit?), innocence from exculpation? So how can we journos comment on results without having seen and heard the witnesses?

Well, because we can.

It’s only one factor in the multiplex calculus of Section 6015(f) for equitable relief, but benefit to the petitioner should figure in.

Lest I be misunderstood, I don’t say Asia Zaheen, Petitioner, and Kamran Ehsan, Intervenor, T. C. Memo. 2025-7, filed 1/22/26, was wrongly decided, nor that Kamran didn’t abuse Asia (that’s Doctor Asia). Judge Courtney D. (“CD”) Jones saw and heard Doctor Asia, Kamran, their two older children, and their housekeeper testify and be cross-examined; I didn’t. 

But one factor gives me pause. Kamran played games with Doctor Asia’s 401(k) while illegally running her medical practice (MA law says nonprofessionals can’t run professional practices), incurring the tax liability at issue here by rolling over and then taking taxable draws therefrom. However, most of the draws went to pay down the mortgage on the medical practice’s real and personal property, all of which Doctor Asia gets in the divorce. Since the debt was north of $260K, that’s no small benefit. And there’s no evidence Kamran enriched himself excessively thereby, except maybe what he took from the practice thereafter (if anything), and then only to the extent of debt service payments no longer due.

True, if Judge CD Jones concluded Kamran was a real nogoodnik (as did the local police and MA Department of Child and Family Services) and Doctor Asia told the truth, then maybe this is the correct way to handle it.

“The income that gave rise to the understatement in this case was used to pay down debt incurred to purchase real estate and medical equipment needed to establish Zaheen Medical Center. Dr. Zaheen is now the sole owner of Zaheen Medical Center, but Mr. Ehsan, at minimum, shared enjoyment of the benefit of the transaction at issue up until Dr. Zaheen filed for divorce. The benefit Dr. Zaheen derived from the understatement is mitigated by the fact that Mr. Ehsan controlled Zaheen Medical Center’s finances and business matters through the year in issue and remitted to Dr. Zaheen only a salary. Additionally, there is no evidence in the record that suggests the parties engaged in a lavish lifestyle. Under these circumstances, we find this factor to be neutral in our analysis.” T. C. Memo. 2025-7, at p. 18.