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considered petitioner’s contentions.” Cheshire v. Commissioner,
115 T.C. at 198. Respondent argues that, considering all facts
and circumstances, the determination that petitioner was not
entitled to equitable relief is consistent with Rev. Proc. 2000-
15, 2000-5 I.R.B. 447, the Internal Revenue Service’s published
guidelines on when equitable relief should be granted.
We have previously found that petitioner did not have actual
knowledge under section 6015(c) of the items giving rise to the
deficiency. The evidence also reflects that petitioner’s
involvement with the Federal income tax returns and corresponding
audits was minimal. Mr. Rowe regularly prepared petitioners’
joint tax returns, and he testified that petitioner had no role
in providing information for the returns. Petitioner testified
that Mr. Rowe provided her with only the first two pages of the
returns, assured her he had records for the returns, and she
trusted him when he said the returns were correct. Mr. Danley,
the accountant who assisted with the preparation of petitioners’
1990 return, testified that he never discussed the 1990 return
with petitioner, she did not provide him with any information,
and she did not have any involvement in the preparation of that
return.
Petitioner also testified that she was unaware of the audits
of petitioners’ taxable years 1987 through 1990 until late 1995
and that she never received any correspondence from the Internal
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