Alicia M. Elias - Page 6

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          available under either subsection.  Washington v. Commissioner,             
          120 T.C. 137, 146-147 (2003); Hopkins v. Commissioner, 121 T.C.             
          73, 88 (2003); Block v. Commissioner, supra.  In this case, there           
          is a deficiency in tax; consequently, petitioner can be                     
          considered for relief under section 6015(b) as well as section              
          6015(c) or (f).                                                             
               Under section 6015(b), a taxpayer is entitled to full or               
          apportioned relief from joint and several liability for an                  
          understatement of tax on a joint return if, among other                     
          requirements, the taxpayer establishes that he or she “did not              
          know, and had no reason to know” that the other spouse                      
          understated the tax on the return.  Sec. 6015(b)(1)(C).  In this            
          case, the adjustments in the notice of deficiency all related to            
          the self-employed business activity of Mr. Elias as an agent for            
          State Farm and, more specifically, the disallowance of certain              
          deductions claimed on the return relating to that activity.                 
          Essentially, the disallowed items included expenses for travel,             
          meals, and entertainment.  Respondent determined, upon                      
          examination of receipts provided by petitioner, that the                    
          disallowed expenses included meals petitioner had consumed, trips           
          that she took, and gasoline, all of which respondent determined             
          were personal expenses that were unrelated to Mr. Elias’s                   
          insurance agency activity.  Some of the expenses were for family            
          trips to Disneyland (a popular resort located in California) and            






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