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understatement and thereby is effectively precluded from
establishing to the contrary.” Id.
Petitioner is not entitled to relief from joint and several
liability under section 6015(b). With respect to the disallowed
rental loss deductions, we find that petitioner was fully aware
of all the underlying factual circumstances concerning the rental
of the condominium unit to her own daughter. Petitioner argues
that, while she may have known of the rental income, she did not
have any knowledge concerning the rental expenses which led to
the losses. Contrary to petitioner’s assertion, the disallowed
loss deductions were the result of the application of the section
469 passive activity loss rules, not the claimed expense
deductions--respondent has not challenged the legitimacy of the
expenses themselves. Thus, petitioner’s request for relief
essentially is based upon ignorance of the law; namely, ignorance
of the passive activity loss limitations of section 469.
Ignorance of the law is not a basis for section 6015(b) relief.
Mitchell v. Commissioner, supra; Cheshire II, supra; Price v.
Commissioner, supra.
With respect to the disallowed charitable contribution
deductions, petitioner did not make a significant contribution
herself, she was unaware of a single contribution made by Mr.
Elesh, and her characterization of Mr. Elesh at trial was of
someone very unlikely to make such large cash contributions.
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