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Petitioner knew of Ms. Becherer’s employment with TTC
Illinois, Trader Publications, and Pennysaver. The three items
of her income from such employment were omitted from the 1996
return. Petitioner aided Ms. Becherer in performing her
employment duties for Trader Publications and Pennysaver.
Petitioner also knew of Ms. Becherer’s employment with TTC
Illinois. Petitioner therefore had an actual and clear awareness
of the existence of the items that gave rise to the deficiency.
Consequently, relief under section 6015(c) is unavailable to
petitioner.
III. Relief Under Section 6015(f)
Respondent argues that he did not abuse his discretion in
denying petitioner equitable relief under section 6015(f).
Respondent’s denial of relief is reviewed under an abuse of
discretion standard. Cheshire v. Commissioner, 115 T.C. at 198;
Butler v. Commissioner, 114 T.C. at 292.
Considering the facts and circumstances of this case, we
held under section 6015(b)(1)(D) that it is not inequitable to
hold petitioner liable for the deficiencies. The language of
section 6015(f)(1), “taking into account all the facts and
circumstances, it is inequitable to hold the individual liable
for any unpaid tax or any deficiency (or any portion of either)”
does not differ significantly from the language of section
6015(b)(1)(D), “taking into account all the facts and
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