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to his financial affairs. Barbara was fully aware of the Vulcan
investment, of the tax benefits to be derived, and of the risk
that those benefits might be challenged by the IRS on audit.
Under the foregoing circumstances, we find that it would not
be inequitable to hold Barbara liable for the deficiencies
arising out of the Vulcan investment.
C. Conclusion
Barbara has failed to satisfy the requirements of either
section 6015(b)(1)(C) or (D).
III. Relief Under Section 6015(c)
A. Statutory Language
Section 6015(c) provides in pertinent part:
SEC. 6015(c). Procedures To Limit Liability for
Taxpayers No Longer Married or Taxpayers Legally
Separated or Not Living Together.--
(1) In general.--Except as provided in this
subsection, if an individual who has made a joint
return for any taxable year elects the application
of this subsection, the individual’s liability for
any deficiency which is assessed with respect to
the return shall not exceed the portion of such
deficiency properly allocable to the individual
under subsection (d).
* * * * * * *
(3) Election.--
(A) Individuals eligible to make election.--
(i) In general.--An individual shall
only be eligible to elect the application of
this subsection if--
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