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equitable relief in situations where relief is unavailable under
section 6015(b) or (c). The parties have treated Barbara's claim
pursuant to section 6013(e) as an election pursuant to section
6015(b)(1) and (2) and a request for equitable relief pursuant to
section 6015(f) that respondent denied. See Corson v.
Commissioner, 114 T.C. 354, 364 (2000); Charlton v. Commissioner,
114 T.C. 333, 338-339 (2000); Butler v. Commissioner, 114 T.C.
276, 282-283 (2000).
We consider first whether Barbara is entitled to relief
under section 6015(b)(1).
Section 6015(b)(1) provides:
(1) In general.--Under procedures prescribed by
the Secretary, if--
(A) a joint return has been made for a
taxable year;
(B) on such return there is an understatement
of tax attributable to erroneous items of one
individual filing the joint return;
(C) the other individual filing the joint
return establishes that in signing the return he
or she did not know, and had no reason to know,
that there was such understatement;
(D) taking into account all the facts and
circumstances, it is inequitable to hold the other
individual liable for the deficiency in tax for
such taxable year attributable to such
understatement; and
(E) the other individual elects (in such form
as the Secretary may prescribe) the benefits of
this subsection not later than the date which is 2
years after the date the Secretary has begun
collection activities with respect to the
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