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(1), establishes that in signing the return
such individual did not know, and had no
reason to know, the extent of such
understatement, then such individual shall be
relieved of liability for tax (including
interest, penalties, and other amounts) for
such taxable year to the extent that such
liability is attributable to the portion of
such understatement of which such individual
did not know and had no reason to know.
Section 6015(c) provides in relevant part:
SEC. 6015(c). Procedures to Limit
Liability For Taxpayers No Longer Married or
Taxpayers Legally Separated or Not Living
Together.--
(1) In general.--Except as
provided in this subsection, if an
individual who has made a joint
return for any taxable year elects
the application of this subsection,
the individual’s liability for any
deficiency which is assessed with
respect to the return shall not
exceed the portion of such
deficiency properly allocable to the
individual under subsection (d).
* * * * * * *
(3)(C) Election not valid with
respect to certain deficiencies.–-If
the Secretary demonstrates that an
individual making an election under
this subsection had actual
knowledge, at the time such
individual signed the return, of any
item giving rise to a deficiency (or
portion thereof) which is not
allocable to such individual under
subsection (d), such election shall
not apply to such deficiency (or
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