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had a business and, therefore, knew that these deposits or
transfers to her account came from that business. Therefore, in
connection with petitioner’s claim for relief, for purposes of
section 6015(b), there was an understatement of tax attributable
to erroneous items of the other spouse, and petitioner, in
signing the return, knew or had reason to know of an
understatement of tax attributable to this income. Sec.
6015(b)(1)(B) and (C). The Court, therefore, sustains
respondent’s determination that petitioner is not entitled to
relief under section 6015(b) for the year 2000.
For the year 2001, the tax return for that year included an
itemized deduction of $21,355 for unreimbursed employee business
expenses. In the audit of the return for that year, respondent
contacted Mr. Clark’s employer, and that employer verified that
these claimed expenses had been reimbursed to Mr. Clark.
Respondent also determined that, as in prior years, unexplained
deposits of $7,038 were made to petitioner’s account during 2001,
all of which were attributable to her husband’s activity. The
Court is satisfied that petitioner knew or had reason to know of
this omitted income in the same fashion as she did for the 2
earlier years. Respondent also determined, as was determined in
earlier years, that the unexplained deposits to her account also
represented income from her husband’s trade or business activity.
The Court holds, therefore, that, in signing the income tax
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