Maureen Monsour - Page 38

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                         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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