- 31 - return, except that we hold that she had knowledge, or reason to know, of Mr. Bennett’s wages and taxable interest. It would not be inequitable to hold her liable for the amounts of which she had knowledge or reason to know. We cannot make a finding about petitioner’s knowledge or reason to know of the remaining community share of $6,125 of income reported on Mr. Bennett’s return. Because the source and nature of this other income is uncertain, we cannot find that it is inequitable to hold her liable for this amount. Therefore, we conclude that petitioner is not entitled to equitable relief with respect to her community share of Mr. Bennett’s reported wages of $20,027, her community share of taxable interest reported on his return of $2,417, or her community share of the $6,125 of unidentified income. In sum, petitioner is liable for tax on gross income of $30,020.50 and is relieved from liability on gross income of $15,692.50 under the flush language of section 66(c). V. Addition to Tax Section 6651(a)(1) imposes an addition to tax for a taxpayer’s failure to file a required return on or before the specified filing due date, including extensions. Section 6651(a)(2) imposes an addition to tax for failing to pay an amount shown on a return. An addition to tax under either section 6651(a)(1) or (2) is inapplicable, however, if thePage: 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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