Craig A. Penfield - Page 9




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          uncorroborated or self-serving testimony.  Tokarski v.                      
          Commissioner, 87 T.C. 74, 77 (1986).  Although petitioner                   
          disputed some of Mrs. Parker's statements, we found Mrs. Parker             
          to be a credible witness.  Petitioner was not credible.  Our                
          evaluation of their testimony is founded upon "the ultimate task            
          of a trier of the facts--the distillation of truth from falsehood           
          which is the daily grist of judicial life."  Diaz v.                        
          Commissioner, 58. T.C. 560, 564 (1972). Accordingly, our analysis           
          below is based primarily on, and limited by, what could be                  
          reliably drawn from the totality of the evidence and testimony.             
               First, we consider whether petitioner is entitled to relief            
          under section 6015(b)(1).  To be entitled to relief under section           
          6015(b)(1), petitioner must satisfy all of the requirements of              
          subparagraphs (A) through (E).  There is no dispute that                    
          petitioner satisfies subparagraphs (A) and (E).                             
               We begin our discussion with subparagraph (C).  Section                
          6015(b)(1)(C) requires that the requesting spouse did not know,             
          or have reason to know, of the erroneous tax return item.  For              
          purposes of section 6015(b) relief, petitioner only contends to             
          lack knowledge with respect to Mrs. Parker’s pension                        
          distributions.  Respondent contends that petitioner knew, or had            
          reason to know, of Mrs. Parker’s pension distributions and,                 
          therefore, fails to satisfy the requirement of subparagraph (C).            
               When the substantial understatement of tax liability is                






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