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former spouse. Sec. 6015(c) and (d); Culver v. Commissioner, 116
T.C. 189, 194 (2001). In the context of a disallowed deduction,
“actual knowledge” under section 6015(c) requires proof that the
spouse seeking relief had actual knowledge of the factual
circumstances which made the item disallowable as a deduction.
Mora v. Commissioner, 117 T.C. 279, 292 (2001); King v.
Commissioner, 116 T.C. 198, 204 (2001).
Isaac argues that the investments in the equipment leasing
partnerships were allocable to Lora and himself and that Lora had
actual knowledge of those investments. As a consequence, Isaac
contends that Lora should not be entitled to relief under section
6015(c). Lora argues that the investments in the equipment
leasing partnerships were allocable to Isaac and that she lacked
actual knowledge of the underlying circumstances resulting in the
disallowance of the deductions relating to these investments.
Lora contends, and respondent has determined, that she meets the
requirements for relief from joint liability under section
6015(c).
We conclude that the equipment leasing partnership
transactions are allocable to Isaac. Isaac made these
investments in his name only. Isaac was a C.P.A. Isaac actively
sought out the investments, and he marketed the investments to
his own clients.
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