- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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