Curtis Earl Moore - Page 8

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          that are attributable to his own erroneous items.  See Hopkins v.           
          Commissioner, 121 T.C. 73, 77 (2003).  The unemployment                     
          compensation was solely attributable to petitioner, and he could            
          not explain why it was omitted from the joint return.  The                  
          disallowed itemized deductions, in the form of medical expense              
          deductions and an employee business expense deduction, are not              
          necessarily attributable to petitioner; however, as more fully              
          discussed infra, petitioner had reason to know of the                       
          understatement in this regard.  Accordingly, we agree with                  
          respondent that petitioner is not entitled to relief under                  
          section 6015(b) as to the unreported unemployment compensation              
          and the disallowed itemized deductions.                                     
               The disallowed Schedule C deductions are a different matter,           
          however.  Respondent does not appear to dispute that petitioner             
          satisfies two elements of section 6015(b)(1); namely, those                 
          regarding joint return and timely election under section                    
          6015(b)(1)(A) and (E), respectively.  Thus, we consider whether             
          petitioner satisfies the remaining three elements of section                
          6015(b) with respect to the Schedule C deductions for Wee Ones              
          Child Care.                                                                 
               One of the three remaining elements of section 6015(b)                 
          requires that the understatement of tax resulting from the                  
          disallowed Schedule C deductions is not attributable to                     
          petitioner.  From a review of this record, we are satisfied that            






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