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such individual did not know and had no reason to know."
Sec. 6015(b)(2).
We agree with respondent that the record of this case
demonstrates that Mrs. Vetrano knew of the portion of the
understatement that is attributable to the payments
received from BMAP. Petitioners admitted that "petitioner-
wife was aware of all the payments that BMAP made to
petitioner-husband." As to the remainder of the
understatement, petitioners failed to introduce any
evidence to show that Mrs. Vetrano did not know and had no
reason to know of the unreported payment from Camden City
Probation. Therefore, we agree with respondent that
Mrs. Vetrano is not eligible for relief under section
6015(b) as to any part of the understatement.
As to relief under section 6015(c), the third issue
in this Supplemental Opinion, section 6015(c)(3)(A) imposes
certain conditions for eligibility to elect relief under
that subsection. To meet the first such condition, the
taxpayer must prove that he or she is no longer married to,
or is legally separated from, the person with whom the
joint return was made, or must prove that he or she was not
a member of the same household with such individual during
the 12-month period ending on the date the election is
filed. See sec. 6015(c)(3)(A)(i).
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