Charma Gatlin Cook - Page 9

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          demonstrating that she had actual knowledge at the time she                 
          signed the joint return of the item giving rise to the                      
          deficiency.                                                                 
          III.  Conclusion                                                            
               Respondent erred in denying petitioner relief under section            
          6015(c).  Petitioner has no liability for the deficiency.                   
               To reflect the foregoing,                                              

                                                   Decision will be entered           
                                             for petitioner.                          






























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