Brenda J. Clarrk - Page 9

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          and records with respect to the determination of taxable income.            
          Since petitioner and her husband’s records were so deficient that           
          respondent was required to employ an indirect method in                     
          determining their income for the years at issue, it is a fair               
          observation that petitioner bears some culpability in the failure           
          to keep books and records.  That alone, however, does not                   
          foreclose petitioner’s entitlement to claim relief from joint               
          liability under section 6015.                                               
               Section 6015(b)(1) allows relief from joint and several                
          liability if five elements are met.  Two of those elements are              
          pertinent in this case:  (1) On the joint return, there is an               
          understatement of tax attributable to erroneous items of one                
          individual filing the return, and (2) the other individual filing           
          the joint return establishes that, in signing the return, he or             
          she did not know, and had no reason to know, that there was such            
          an understatement.  Sec. 6015(b)(1)(A), (B), and (C).  With                 
          respect to the year 1998, in the examination of petitioner’s bank           
          accounts, which included one bank account of petitioner and a               
          joint account with her husband, respondent determined that                  
          several deposits into these accounts, totaling $9,131,                      
          constituted unreported gross income.  Another item of                       
          significance was the claimed deduction for moving expenses in the           
          amount of $35,304 on the 1998 return.  In the audit of the                  
          returns, petitioner readily admitted that such an amount for                






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