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(E) the other individual elects * * * the benefits
of this subsection not later than the date which is 2
years after the date the Secretary has begun collection
activities with respect to the individual making the
election * * *
All of the requirements must be met, and failure to meet
even one of the requirements is a bar to relief. Sec.
6015(b)(1); Alt v. Commissioner, 119 T.C. 306, 313 (2002).
Respondent concedes that petitioner has satisfied the
requirements of subparagraphs (A), (B), and (E) of section
6015(b)(1). Therefore, we must decide whether petitioner has met
the requirements of subparagraphs (C) and (D), to wit: Whether
petitioner, when signing the return, knew or had reason to know
that there was a substantial understatement and/or whether,
taking into account all of the facts and circumstances, it would
be inequitable to hold petitioner liable for the understatement.
Petitioner contends, in the alternative, that respondent, on
the basis of the holding of a prior case, is collaterally
estopped from denying that she did not know or have a reason to
know of the understatements and/or that she is entitled to relief
based on the facts presented in this case. We begin our
consideration here with the question of collateral estoppel.
I. Is Respondent Collaterally Estopped?
A. In General
Petitioner argues that respondent is collaterally estopped
from denying that petitioner did not know or have reason to know
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