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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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