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each other but merely divided responsibility for monthly bills.
Petitioner did not know how much or how often Ms. DeFore received
payment from Mr. Hall. Petitioner testified he had “no earthly
idea” how much money Ms. DeFore received from Mr. Hall in 2001.
The Court has no reason not to believe him. Moreover, petitioner
believed and knew that Ms. DeFore worked for Mr. Hall; however,
the record does not suggest a finding that petitioner knew that
Ms. DeFore’s compensation for her services for Mr. Hall came from
three separate sources. Petitioner believed that the one
information return Ms. DeFore presented to the income tax return
preparer reflected her sole earnings that year. Petitioner,
therefore, had no actual knowledge that there were two
undisclosed information returns from Mr. Hall that would fully
represent Ms. DeFore’s income for 2001. Therefore, petitioner
qualifies for relief under section 6015(c).5 Thus, the
procedures in section 6015(d) to allocate items between
petitioner and Ms. DeFore apply.
For purposes of section 6015(c), the item giving rise to the
deficiency on a joint return is allocated as if the individuals
had filed separate returns. Sec. 6015(d)(3)(A). Since the
understatement in tax is entirely attributable to Ms. DeFore’s
omitted income, it follows that the entire amount of the
5 Because the Court has granted petitioner relief under
sec. 6015(c), it is not necessary to address whether petitioner
also qualifies for relief under sec. 6015(f).
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