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6015(b) and, in particular, that she had no knowledge or reason
to know of the understatement attributable to the Hoyt
partnership items on the joint returns. Petitioner further
alleged that she was entitled to an allocation of liability under
section 6015(c) because she was no longer married, did not have
actual knowledge of any items giving rise to the deficiency when
she signed the returns, and all of the items giving rise to the
deficiency were allocable to Mr. Owen because he made the
decision to invest in DGE. Petitioner also argued that she was
entitled to equitable relief under section 6015(f).
On August 28, 2001, respondent sent petitioner a preliminary
determination denying petitioner’s request for relief under
section 6015(b), (c), and (f). In the Form 886-A, Explanation of
Items, attached to the preliminary determination, respondent
explained the denial of relief under section 6015(c) as follows:
We have concluded that you had actual knowledge of the
item giving rise to the understatement. The following
factors were considered in reaching this conclusion:
• You signed one or more
partnership/subscription agreements/powers of
attorney with respect to the Hoyt
partnerships.
• You signed personal checks made payable to
W.J. Hoyt Sons or other Hoyt entity [sic].
• You signed other correspondence/documents
relating to the Hoyt partnerships.
• You are not eligible for relief under section
6015(c) with respect to your own erroneous
items and you have not shown that the
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