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NCNB account to make the mortgage interest payments in 1990.20
As we mentioned earlier, the record indicates that petitioner saw
the first two pages only of the tax returns, and she was not
afforded the opportunity to see or review any attachments,
schedules, or other documents pertaining to the returns. Thus,
petitioner would not have known that a portion of the interest
payments was deducted as both a Schedule A itemized deduction and
a Schedule F interest expense. Respondent has not established
that petitioner had actual knowledge of the factual circumstances
which limited the 1990 Schedule A mortgage interest to $66,105.
Accordingly, we hold petitioner is entitled to relief from joint
liability under section 6015(c) for the portion of this item
allocable to Mr. Rowe.
IV. Farming Activity Losses
A. Background
During the years in issue, Mr. Rowe owned and showed horses.
Petitioner had little or no involvement in this horse activity.
In 1987, Mr. Rowe employed Joseph and Patricia Shortino (the
Shortinos) as horse trainers, and they showed and stabled Mr.
Rowe’s horses during the years in issue.21 The Shortinos had
20We note that Mr. Rowe testified that at some point during
the years in issue he took over the responsibility of making the
mortgage payments.
21Mr. Rowe first met Joseph and Patricia Shortino (the
Shortinos) in 1985, and they became personal friends of
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