Shuang-Di Sun Bennett - Page 20

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          petitioner knew, or had reason to know, about Mr. Bennett’s wages           
          of $40,054.                                                                 
               Similarly, in regard to her share of the $4,834 of taxable             
          interest, petitioner was aware that the couple had joint bank               
          accounts.  As a result, petitioner knew, or had reason to know,             
          of the taxable interest income.                                             
               With regard to her share of the remaining $12,250 of                   
          unidentified community income, we do not have enough information            
          to evaluate whether petitioner knew or had reason to know of this           
          income.  Therefore, for purposes of section 66(c)(3), petitioner            
          has not established that she did not know, and had no reason to             
          know, of the unidentified income.                                           
               Accordingly, we hold that she is not entitled to relief from           
          any of the items of community income reported on Mr. Bennett’s              
          return under section 66(c)(3).                                              
          IV.  Equitable Relief Under the Flush Language of Section 66(c)             
               The flush language of section 66(c) provides:                          
               Under procedures prescribed by the Secretary, if,                      
               taking into account all the facts and circumstances, it                
               is inequitable to hold the individual liable for any                   
               unpaid tax or any deficiency (or any portion of either)                
               attributable to any item for which relief is not                       
               available under the preceding sentence, the Secretary                  
               may relieve such individual of such liability.[11]                     

               11  The flush language providing equitable relief was added            
          to sec. 66(c) as part of the Internal Revenue Service                       
          Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3201,           
          112 Stat. 734, the same section of the same legislation that                

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