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Opinion is whether Mrs. Vetrano is eligible for relief
under section 6015(b). Section 6015(b) is applicable to
all joint filers who elect relief under that subsection and
who establish that they meet the four other requirements
set forth therein. The other requirements are similar to
the requirements that were prescribed by former section
6013(e). See Butler v. Commissioner, 114 T.C. at 283.
One of those requirements is that the individual
seeking relief under section 6015(b) establish "that in
signing the return he or she did not know, and had no
reason to know" that there was an understatement
attributable to the erroneous items of the other spouse.
Sec. 6015(b)(1)(C); see Cheshire v. Commissioner, 115 T.C.
183, 192-193 (2000). Notwithstanding the individual's
knowledge or reason to know of some part of the
understatement, section 6015(b)(2) permits the individual
to qualify for relief as to the remainder of the
understatement, if the individual establishes that in
signing the return he or she did not know, and had no
reason to know, the extent of the understatement. See sec.
6015(b). In that case, the individual will be relieved of
liability for tax "to the extent that such liability is
attributable to the portion of such understatement of which
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