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he provided petitioner with any information regarding charitable
contributions. In the instant case, petitioner had no reason to
believe that Mr. Rowe had not contributed to the church in 1988
and 1989 in the same manner as petitioners contributed in prior
years. Under the circumstances presented in this case,
respondent has failed to show that petitioner had actual
knowledge that the charitable contributions were not made in 1988
and 1989. Accordingly, we hold that petitioner is entitled to
relief from joint liability under section 6015(c) for the portion
of this item allocable to Mr. Rowe.
VI. Application of Section 6015(b)
Petitioner claims that she is entitled to complete relief
from liability under section 6015(b) with respect to the items
giving rise to the deficiency. One requirement of section
6015(b) is that the understatement of tax be attributable to
erroneous items of the nonelecting spouse. Sec. 6015(b)(1)(B).
We previously granted petitioner complete relief under section
6015(c) for the IRA distributions and farming activity losses.
We also granted petitioner partial relief under section 6015(c)
for the half of the capital gains, mortgage interest, and
charitable contributions items which we found are allocable to
Mr. Rowe. Thus, the only items remaining are the half of the
capital gains, mortgage interest, and charitable contributions
which are allocable to petitioner. Consequently, petitioner is
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