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premised solely on ignorance of law. * * * In such a
scenario, regardless of whether the spouse possesses
knowledge of the tax consequences of the item at issue,
she is considered as a matter of law to have reason to
know of the * * * understatement * * *.
Therefore, applying the approach of Price v. Commissioner, supra,
we find that Barbara had reason to know of the understatements.
3. Section 6015(b)(1)(D)
a. Introduction
Because the requirements of section 6015(b)(1) are stated in
the conjunctive, Barbara’s failure to satisfy the lack of
knowledge requirement of section 6015(b)(1)(C) is a sufficient
condition for us to find that she does not qualify for relief
under section 6015(b). Nevertheless, since, in light of the
facts and circumstances of this case, we believe that it would
not be inequitable to hold her liable for the deficiencies, we
discuss the application of section 6015(b)(1)(D).
b. Discussion
The requirement, in section 6015(b)(1)(D), that it be
inequitable to hold the requesting spouse liable for an
understatement on a joint return, is virtually identical to the
same requirement of former section 6013(e)(1)(C). Therefore, as
in the case of the no-knowledge-of-the-understatement requirement
of section 6015(b)(1)(C), cases interpreting former section
6013(e) remain instructive as to our analysis. See Butler v.
Commissioner, 114 T.C. at 283.
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