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petitioner’s alleged fear of Mr. Capehart did not prevent her in
the past from trying to convince him that she should obtain
employment outside the home, and he did not abuse her when she
eventually did so. This positive factor does not apply. Ewing
v. Commissioner, supra at 46; Washington v. Commissioner, 120
T.C. at 149.
d. No Knowledge or Reason To Know
The tax liabilities at issue in this case arose from
deficiencies. Petitioner argues that she did not know or have
any reason to know of the items giving rise to those
deficiencies.
Although we have not specifically discussed the meaning of
the phrase “item giving rise to the deficiency” in the context of
section 6015(f), we have considered whether a requesting spouse
had culpable knowledge for purposes of section 6015(f). See,
e.g., Bartak v. Commissioner, T.C. Memo. 2004-83; Ellison v.
Commissioner, T.C. Memo. 2004-57. In addition, we have
specifically interpreted the phrase in deciding whether a
taxpayer qualifies for relief under section 6015(c). In King v.
Commissioner, 116 T.C. 198, 202-203 (2001), a case involving a
deficiency resulting from erroneous deductions, we decided
whether a taxpayer had “actual knowledge of the item giving rise
to the deficiency” under section 6015(c)(3)(C). There, we held
that section 6015(c)(3)(C), which provides an exception to a
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