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Barbara under section 6015(c). Respondent does not challenge
David’s authority, as personal representative, to make such
election. Respondent challenges petitioners’ claim that Barbara
satisfies the eligibility requirements. Petitioners claim that,
on June 13, 2000, Barbara (having died more than 4 years earlier)
was not married to David and had not been part of his household
for more than 1 year, thereby satisfying two of the three
alternative eligibility requirements of section 6015(c)(3)(A)(i).
Respondent further argues that, even if we were to decide that
Barbara satisfies the eligibility requirements, David cannot make
a valid election with respect to the understatements because
respondent has demonstrated that, at the time Barbara signed the
joint returns, she had actual knowledge of the items giving rise
to the understatements (i.e. the Vulcan transaction). See sec.
6015(c)(3)(C). Because we agree with respondent that Barbara did
not satisfy the eligibility requirements, we need not determine
whether David’s election was invalid solely on account of section
6015(c)(3)(C).
2. Eligibility
a. Introduction
Section 6015(a)(2) provides that an individual who has made
a joint return (and who is eligible to elect the application of
section 6015(c)) may elect to limit his or her joint return
liability in the manner prescribed in section 6015(c). Nowhere
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