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Rowe’s determination that there was no gain. Additionally,
petitioner contends that she was unaware that the Anorada
property was sold in 1988 and that it should have been reported
on the 1988 return.
In Charlton v. Commissioner, 114 T.C. 333 (2000), we found
that although the electing spouse had actual knowledge of income
from a particular source and knew generally of the source of the
income, he had no knowledge that all income from that source had
not been accounted for as reported. Thus, we held that the
electing spouse qualified for relief under section 6015(c)
because “respondent has not shown that Charlton had actual
knowledge of the item causing the deficiency”. Id. at 341. A
few months later, in Cheshire v. Commissioner, 115 T.C. 183
(2000), we held that where the spouse claiming relief under
section 6015(c) had actual knowledge of the omitted income but
did not have knowledge “whether the entry on the return is or is
not correct”, relief was not available. Id. at 195. In Martin
v. Commissioner, T.C. Memo. 2000-346, we discussed generally our
decisions in Charlton v. Commissioner, supra, and Cheshire v.
Commissioner, supra. We concluded that actual knowledge of a
disputed item of income and the amount thereof prevents a
taxpayer from claiming relief from joint liability under section
6015(c). Id. We noted that where an electing spouse has actual
knowledge of an income source, but no knowledge of the amount of
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