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6015(a). If relief is not available under section 6015(b) or
(c), a requesting spouse may seek equitable relief under section
6015(f). Sec. 6015(f)(2).
A prerequisite to granting relief under section 6015(b) or
(c) is the existence of a tax deficiency or, as referred to in
various cases, an “understatement of tax”. Sec. 6015(b)(1)(B)
and (c)(1); Block v. Commissioner, 120 T.C. 62, 65-66 (2003). In
this case, there are understatements of tax; consequently,
petitioner is entitled to consideration for relief under section
6015(b) and (c) as well as section 6015(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 the examination of petitioner’s joint returns for the 3
years at issue, because of inadequate records respondent
determined the taxable income of petitioner and her spouse by use
of the bank deposits method. The issue in this case,
petitioner’s entitlement to relief from joint liability, to some
extent is predicated on her personal background in education and
work experience in areas of business and accounting. Petitioner,
therefore, knew or should have known of the necessity of books
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