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(A) a joint return has been made for a
taxable year;
(B) on such return there is an
understatement of tax attributable to
erroneous items of 1 individual filing the
joint return;
(C) 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
understatement;
(D) taking into account all the facts
and circumstances, it is inequitable to hold
the other individual liable for the
deficiency in tax for such taxable year
attributable to such understatement; and
(E) the other individual elects (in such
form as the Secretary may prescribe) the
benefits of this subsection not later than
the date which is 2 years after the date the
Secretary has begun collection activities
with respect to the individual making the
election,
then the other individual shall be relieved of
liability for tax (including interest, penalties,
and other amounts) for such taxable year to the
extent such liability is attributable to such
understatement.
Section 6015(b)(1) is similar to section 6013(e)(1). We may
look at cases interpreting section 6013(e)(1) for guidance when
analyzing parallel provisions of section 6015. See Jonson v.
Commissioner, 118 T.C. 106, 119 (2002), affd. 353 F.3d 1181 (10th
Cir. 2003). The failure by a spouse requesting relief (request-
ing spouse) under section 6015(b) to satisfy any of the require-
ments of that section prevents such spouse from qualifying for
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