Shuang-Di Sun Bennett - Page 28

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          or reason to know of her purported wages.  We previously found              
          that Mr. Bennett forbade her to open mail and thus, we believe              
          petitioner’s testimony that she never saw the Form W-2.                     
               In sum, we conclude that petitioner did not have knowledge,            
          or reason to know, of the $31,385 of purported wages, but that              
          she knew, or had reason to know, of the $723 of taxable interest            
          and $2,180 of income from an IRA distribution.  This factor                 
          weighs in favor of equitable relief with respect to the wage                
          income, but against granting equitable relief from the taxable              
          interest and IRA distributions reported on her original return.             
                    2. Knowledge, or Reason To Know, About the Items of               
                       Community Property Reported on Mr. Bennett’s Return            
               We have previously held during our discussion on section               
          66(c)(3) that petitioner had knowledge, or reason to know, about            
          Mr. Bennett’s wages and the interest income reported on his                 
          return.  With respect to the $6,125 of unidentified income                  
          reported on Mr. Bennett’s return, we were unable to determine               
          whether petitioner knew of these items, but held for purposes of            
          section 66(c)(3) that petitioner could not establish that she did           
          not know, or have reason to know, about the income.  Thus, in               
          regard to Mr. Bennett’s wages and taxable interest, this factor             
          weighs against equitable relief but is relatively neutral with              
          respect to the $6,125 of unidentified income reported on Mr.                
          Bennett’s return because we do not have enough information to               
          evaluate her knowledge or reason to know.                                   

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