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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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