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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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