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understatement. See Guth v. Commissioner, 897 F.2d 441, 443-444
(9th Cir. 1990), affg. T.C. Memo. 1987-522; Cheshire v.
Commissioner, 115 T.C. 183 (2000), affd. 282 F.3d 326 (5th Cir.
2002); Braden v. Commissioner, T.C. Memo. 2001-69. Accordingly,
in such circumstances, innocent spouse relief is denied.
Petitioner knew of Ms. Becherer’s employment with TTC
Illinois, Trader Publications, and Pennysaver. Ms. Becherer’s
income from these employers was not included on the 1996 Federal
income tax return. We conclude that petitioner had reason to
know of Ms. Becherer’s understatement of income. Therefore,
petitioner does not satisfy the requirement of section
6015(b)(1)(C).
C. Section 6015(b)(1)(D): Inequitable To Hold Liable
The requirement in section 6015(b)(1)(D), that it be
inequitable to hold the requesting spouse liable for an
understatement on a joint return, is virtually identical to the
requirement of former section 6013(e)(1)(D); therefore, cases
interpreting former section 6013(e) remain instructive to our
analysis. Butler v. Commissioner, supra at 283.
Whether it is inequitable to hold a spouse liable for a
deficiency is determined “taking into account all the facts and
circumstances”. Sec. 6015(b)(1)(D). The most often cited
material factors to be considered are (1) whether there has been
a significant benefit to the spouse claiming relief, and (2)
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