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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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