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not entitled to relief under section 6015(b) for the capital
gains, mortgage interest, and charitable contributions which are
allocable to her because these are not erroneous items “of” Mr.
Rowe.
VII. Application of Section 6015(f)
Petitioner claims that, to the extent she fails to qualify
for relief under section 6015(b) or (c), she is entitled to
equitable relief under section 6015(f). We previously found that
the capital gains, mortgage interest, and charitable
contributions items are allocable evenly between petitioner and
Mr. Rowe for purposes of section 6015(c). We also held that
petitioner did not have actual knowledge of any of these items,
and, thus, she is entitled to relief under section 6015(c) for
the portions of the items allocable to Mr. Rowe. Thus, the
question is whether petitioner is entitled to equitable relief
under section 6015(f) for the portion of the capital gains,
mortgage interest, and charitable contributions items giving rise
to deficiencies which are allocable to her.
Petitioner’s claim for relief from joint liability was
initiated in her amended petition to this Court. Before trial,
respondent conceded that petitioner was entitled to relief with
respect to certain items contained in the notices of deficiency.
We must presume that “before doing so, respondent followed
standard procedures by reviewing his administrative files and
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