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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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