- 27 - 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.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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