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the time such individual signed the return, of any item giving
rise to a deficiency (or portion thereof) which is not allocable
to such individual”. Sec. 6015(c)(3)(C); Culver v. Commissioner,
116 T.C. 189, 194-195 (2001); Cheshire v. Commissioner, supra at
193-194.
Respondent argues that petitioner had actual knowledge of
the unreported income because: (1) She had access to the
proceeds of Mr. Glaze’s wage income from Mayflower in the joint
checking account; (2) she occasionally reviewed the bank
statements regarding their joint checking account; (3) she used
moneys from Mr. Glaze’s wage income to pay joint household
expenses; and (4) the interest income received from the U.S.
Treasury was received jointly by petitioner and Mr. Glaze.
In the present case, “the knowledge standard for purposes of
section 6015(c)(3)(C) is an actual and clear awareness * * * of
the existence of an item which gives rise to the deficiency”.
Cheshire v. Commissioner, supra at 195.
Petitioner is not entitled to relief from joint and several
liability under section 6015(c). As discussed above, petitioner
had actual knowledge of the $24 of interest income. Also, as
discussed above, petitioner was fully aware of all the underlying
factual circumstances concerning the wage income received by Mr.
Glaze from Mayflower. See Cheshire v. Commissioner, supra.
Consequently, petitioner had actual knowledge of the factual
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