- 38 -
circumstances, it is inequitable to hold the
other individual liable for the deficiency in
tax for such taxable year attributable to such
understatement; and
(E) the other individual elects (in such
form as the Secretary may prescribe) the bene-
fits of this subsection not later than the
date which is 2 years after the date the Sec-
retary has begun collection activities with
respect to the individual making the election,
* * *
Section 6015(b)(1) is similar to section 6013(e)(1). We may
look at cases interpreting section 6013(e)(1) for guidance when
analyzing parallel provisions of section 6015. See Jonson v.
Commissioner, 118 T.C. at 119. The failure by a spouse requesting
relief (requesting spouse) under section 6015(b) to satisfy any of
the requirements of that section prevents such spouse for qualify-
ing for such relief. Alt v. Commissioner, 119 T.C. 306, 313
(2002), affd. 101 Fed. Appx. 34 (6th Cir. 2004).
The parties agree that petitioner satisfies section
6015(b)(1)(A) and (E). Petitioner contends, and respondent
disputes, that she satisfies section 6015(b)(1)(B), (C), and (D).
Section 6015(b)(1)(B)
In order to satisfy section 6015(b)(1)(B), petitioner must
establish that there is an understatement of tax for each of the
taxable years 1989, 1991, 1992, and 1993 that is attributable to
erroneous items of Mr. Monsour. It is petitioner’s position that
The testimony of * * * [Mr. Monsour and Mr.
Laubach] delineated the issues before the Court that led
to the understatements [sic] for each year * * *. All
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