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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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