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seek relief. Stevens v. Commissioner, 872 F.2d 1499, 1505 (11th
Cir. 1989), affg, T.C. Memo. 1988-63; Butler v. Commissioner, 114
T.C. 276, 284 (2000). When taxpayers fail to fulfill their duty
of inquiry, they are ordinarily charged with constructive
knowledge of any understatements on their returns. See Hayman v.
Commissioner, 992 F.2d 1256, 1262 (2d Cir. 1993), affg. T.C.
Memo. 1992-228; Crowley v. Commissioner, T.C. Memo. 1995-551,
affd. without published opinion sub nom. Cockrell v.
Commissioner, 116 F.3d 1472 (2d Cir. 1997); Cohen v.
Commissioner, T.C. Memo. 1987-537 (the provisions providing
relief from joint and several liability are “designed to protect
the innocent, not the intentionally ignorant”). Petitioner has
not satisfied her burden here.
Moreover, on the entire record of petitioner’s enjoyment of
the fruits of the consistent pattern of underpayment of taxes and
of her subsequent efforts to defeat collection efforts of the
IRS, we cannot conclude that it would be inequitable to hold her
liable for the deficiencies in tax in issue in this case. She is
not entitled to relief under section 6015(b).
Section 6015(c) Analysis
Section 6015(c) allows a taxpayer, who is eligible and so
elects, to limit his or her liability to the portion of a
deficiency that is properly allocable to the taxpayer as provided
in section 6015(d). Sec. 6015(c)(1). Under section
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