Verna Doyel - Page 19

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          joint investor with her husband.                                            
               Finally, Christopher may have taken the initiative and                 
          researched the Hoyt investment, but petitioner agreed to invest             
          in the Hoyt partnerships and she did it jointly with Christopher.           
          All investment decisions in the Doyel household were made jointly           
          by petitioner and Christopher.                                              
               Accordingly, we conclude that the understatements are not              
          attributable to the erroneous items of one individual filing the            
          joint returns.                                                              
                    2.   Section 6015(b)(1)(C):  Know or Reason To Know               
               The requirement in section 6015(b)(1)(C), the no-knowledge-            
          of-the-understatement requirement, is virtually identical to the            
          same requirement of former section 6013(e)(1)(C); therefore,                
          cases interpreting former section 6013(e) remain instructive to             
          our analysis.  Jonson v. Commissioner, supra at 115; Butler v.              
          Commissioner, 114 T.C. 276, 283 (2000).                                     
               The relief-seeking spouse knows of an understatement of tax            
          if she knows of the transaction that gave rise to the                       
          understatement.  E.g., Purcell v. Commissioner, 826 F.2d 470,               
          473-474 (6th Cir. 1987), affg. 86 T.C. 228 (1986).  The relief-             
          seeking spouse has reason to know of an understatement if she has           
          reason to know of the transaction that gave rise to the                     
          understatement.  E.g., Bokum v. Commissioner, 94 T.C. 126, 146              
          (1990), affd. 992 F.2d 1132 (11th Cir. 1993).  Courts                       






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