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would be inequitable to hold her liable for the deficiency in tax
attributable to the understatement. In view of petitioner’s
education, we do not accept her generalized allegations that she
knew nothing about tax matters for the years in issue. She did
not file timely returns for 1992, 1993, or 1994, even though she
received compensation as a school teacher during those years.
She acknowledges that, at the time the returns were filed, she
was represented by an attorney and a certified public accountant.
Petitioner and Robledo lived in a community property State and
together owned rental real estate, some of which petitioner was
awarded in the divorce decree. Petitioner seeks to be relieved
of liability for taxes on her own income as well as that of
Robledo, asserting that she was unfairly treated in the divorce
proceedings and in the bankruptcy court. She has not satisfied
the requirements for relief under section 6015(b). (The relief
that she was granted under section 6015(c) includes any relief
that she might have claimed under section 6015(b) with respect to
items attributable solely to Robledo.)
For the same reasons, and applying the factors discussed
with respect to 1990, we cannot conclude that denial of relief to
petitioner under section 6015(f) was an abuse of discretion.
We have considered the other arguments made by petitioner. They
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