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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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