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withdrawal, and savings bond interest), and it would not be
inequitable to hold her liable for the tax.
In limited situations, taxpayers filing joint Federal income
tax returns may be relieved of joint liability pursuant to
section 6015. Petitioner is not entitled to relief under section
6015(b) if she had reason to know of the items of income. Sec.
6015(b)(1)(C). Similarly, petitioner is not entitled to relief
under section 6015(c) if she had actual knowledge of the item
giving rise to the omitted income. Sec. 6015(c)(3)(C); Cheshire
v. Commissioner, 115 T.C. 183, 197 (2000), affd. 282 F.3d 326
(5th Cir. 2002).
We agree with respondent that petitioner had actual
knowledge of Mr. Orsino’s compensation relating to Betz Dearborne
and National Engineering and his 401(k) withdrawal. Accordingly,
with respect to Mr. Orsino’s compensation and 401(k) withdrawal,
petitioner is not entitled to relief pursuant to section 6015(b)
or (c).
Petitioner, however, did not have clear awareness of the
interest income relating to the savings bond. Cf. Cheshire v.
Commissioner, supra at 197 (holding that knowledge of her
husband’s pension withdrawal disqualified the taxpayer from
section 6015 relief even though the taxpayer did not know the tax
consequences of the transaction). Petitioner was led to believe
that Mr. Orsino received a cash gift from his mother. She did
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