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any reason to know of the items giving rise to those
deficiencies. In order to ascertain the level of the requesting
spouse’s knowledge of the items giving rise to the deficiency for
purposes of section 6015(f), we must examine whether the
requesting spouse knew or had reason to know of the factual basis
for the denial of the deductions. Capehart v. Commissioner, T.C.
Memo. 2004-268; see also Mora v. Commissioner, 117 T.C. at 291-
292; King v. Commissioner, 116 T.C. 198, 204 (2001).
With respect to section 6015(f), our review of the record
convinces us that petitioner did not have actual knowledge of the
items giving rise to the deficiency. However, we still must
decide whether petitioner had reason to know of the items giving
rise to the deficiency. In order to resolve the issue, we must
examine whether and to what extent petitioner had reason to know
of the factual basis for respondent’s adjustment to the Hoyt
partnership loss deductions and the IRA deduction claimed by
petitioner and her husband during the years at issue.
At the time she filed her petition, petitioner resided in
Oregon. In the absence of a stipulation to the contrary, the
U.S. Court of Appeals for the Ninth Circuit is presumably the
proper venue for an appeal in this case. See sec. 7482(b)(2).
We believe that the Court of Appeals would require an analysis of
the “reason to know” requirement like the one it articulated in
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