Curtis Earl Moore - Page 15

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               The two factors which we consider of most importance weigh             
          against section 6015(f) relief.  The first factor is the item for           
          which relief is sought is solely attributable to petitioner.  We            
          have fully discussed this above and concluded that the omitted              
          unemployment insurance and the disallowed itemized deductions are           
          attributable to petitioner.  The second factor is knowledge or              
          reason to know of the items giving rise to the deficiency.                  
          Petitioner had knowledge or reason to know of the items giving              
          rise to the deficiency.  We are satisfied that petitioner had               
          actual knowledge of the omitted unemployment insurance income,              
          and the itemized deductions.  For example, petitioner gave Ms.              
          Moore a list representing employee business expenses totaling               
          approximately $600.  The return, prepared by Ms. Moore, reflected           
          $3,889 in employee business expense.  Petitioner cannot escape              
          liability for items of income or deductions which are                       
          attributable to him and of which he had knowledge, by not                   
          reviewing the tax return.                                                   
               Considering the above analysis, we conclude that respondent            
          did not abuse his discretion in denying relief under section                
          6015(f), as to the portion of deficiency resulting from the                 
          omitted unemployment income and disallowed itemized deductions.             











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