Charma Gatlin Cook - Page 1

                                 T.C. Memo. 2005-22                                   

                               UNITED STATES TAX COURT                                

                          CHARMA GATLIN COOK, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 17166-02.            Filed February 10, 2005.               

                    R determined a deficiency in Federal income tax                   
               with respect to the joint return for 1998 made by P and                
               her then husband (which determination P did not                        
               contest); R denied P’s subsequent request for relief                   
               from joint and several liability under I.R.C. sec.                     
               6015(b), (c), or (f).                                                  
                    1.  Held:  P is eligible to elect relief under                    
               I.R.C. sec. 6015(c), and R has failed to nullify the                   
               election by demonstrating that she had actual knowledge                
               at the time she signed the joint return of the item                    
               giving rise to the deficiency.                                         
                    2.  Held, further, R erred in denying P relief                    
               under I.R.C. sec. 6015(c).                                             
                    3.  Held, further, P has no liability for the                     

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