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               A.   Full/Apportioned Relief                                           
               Section 6015(b) provides full/apportioned relief from joint            
          liability on a joint return to the extent that the liability is             
          attributable to an understatement of tax.  To be eligible for               
          this relief, a requesting spouse needs to satisfy the following             
          five elements of section 6015(b)(1):                                        
                    (A) a joint return has been made for a taxable                    
               year;                                                                  
                    (B) on such return there is an understatement of                  
               tax attributable to erroneous items of 1 individual                    
               filing the joint return;                                               
                    (C) the other individual filing the joint return                  
               establishes that in signing the return he or she did                   
               not know, and had no reason to know, that there was                    
               such understatement;                                                   
                    (D) taking into account all the facts and                         
               circumstances, it is inequitable to hold the other                     
               individual liable for the deficiency in tax for such                   
               taxable year attributable to such understatement; and                  
                    (E) the other individual [timely] elects (in such                 
               form as the Secretary may prescribe) the benefits of                   
               this subsection * * *.                                                 
          The requesting spouse’s failure to meet any one of these                    
          requirements prevents him or her from qualifying for                        
          full/apportioned relief.  Alt v. Commissioner, supra at 313.                
               Respondent concedes that the requirements of subparagraphs             
          (A) and (E) have been met and argues that petitioner does not               
          meet the requirements set forth in the remaining three                      
          subparagraphs.  On the basis of our findings, we agree with                 
          respondent that petitioner does not qualify for full/apportioned            
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