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spouse, and she knew that he deposited the income received from
these sources into their joint bank account. Moreover,
petitioner admitted in her Form 12510, Questionnaire for
Requesting Spouse, that she reviewed their monthly bank
statements and paid household expenses out of the very account
into which Mr. Lathrop deposited all income he received during
the year at issue. Petitioner’s testimony establishes actual
knowledge on her part that Mr. Lathrop received both unemployment
compensation and nonemployee compensation during the year at
issue. Her basis for requesting relief was that, as she had not
reviewed the return, she was unaware that Mr. Lathrop had not
included the entirety of these items of income on their return
for the year at issue.
Section 6015 relief was not intended to provide relief to
spouses who simply did not look at the amount of income reported
on the return, unless it is clearly established that the spouse
was forced under duress to sign the return without reviewing it.
Frederick v. Commissioner, T.C. Memo. 1981-602. The record does
not support a finding that petitioner was forced to sign the
return under duress. A spouse requesting relief under section
6015 has a duty of inquiry. Butler v. Commissioner, supra at
284. A requesting spouse has reason to know of an understatement
if a “reasonably prudent person with knowledge of the facts
possessed by the person claiming * * * [relief] should have been
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