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intentional deception of petitioner about the underlying
circumstances that gave rise to the understatement. Although we
may consider other factors in addition to those set forth in Rev.
Proc. 2000-15, supra, we have previously rejected petitioner’s
argument and denied innocent spouse relief in cases where neither
spouse knew of the facts that provided the basis for the
disallowance of partnership losses on their joint returns.
Capehart v. Commissioner, supra; Bartak v. Commissioner, T.C.
Memo. 2004-83; Ellison v. Commissioner, T.C. Memo. 2004-57; Doyel
v. Commissioner, T.C. Memo. 2004-35. The purpose of section 6015
is to protect one spouse from the overreaching or dishonesty of
the other spouse. Bartak v. Commissioner, supra (citing Purcell
v. Commissioner, 826 F.2d 470, 475 (6th Cir. 1987), affg. 86 T.C.
228 (1986)). Where the understatement is attributable to the
mistaken belief of both the requesting spouse and the other
spouse as to the legitimacy of the tax shelter deductions, we
have held that it is not inequitable to hold both spouses jointly
and severally liable. Bokum v. Commissioner, 94 T.C. 126, 146
(1990), affd. 992 F.2d 1132 (11th Cir. 1993); McCoy v.
Commissioner, 57 T.C. 732, 735 (1972); Bartak v. Commissioner,
supra; Ellison v. Commissioner, supra; Doyel v. Commissioner,
supra.
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