Shuang-Di Sun Bennett - Page 32

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          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 the                  







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