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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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