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such relief. Alt v. Commissioner, 119 T.C. 306, 313 (2002),
affd. 101 Fed. Appx. 34 (6th Cir. 2004).
The parties agree that petitioner satisfies section
6015(b)(1)(A), (B), and (E). Petitioner argues, and respondent
disputes, that she satisfies section 6015(b)(1)(C) and (D).
Section 6015(b)(1)(C)
Pursuant to section 6015(b)(1)(C), petitioner must establish
that in signing the 1982 joint tax return she did not know, and
had no reason to know, of the understatement of tax in that
return attributable to the claimed $58,089 Madison Recycling loss
and the claimed Madison Recycling tax credits of $114,407 (under-
statement in the 1982 joint tax return).
Respondent does not dispute that in signing the 1982 joint
tax return petitioner did not have actual knowledge of the
understatement in the 1982 joint tax return. The parties dispute
whether in signing the 1982 joint tax return petitioner had
reason to know of the understatement in the 1982 joint tax
return.
According to respondent, petitioner had constructive knowl-
edge of the items reported in the 1982 joint tax return. Respon-
dent is correct that a taxpayer who signs a tax return without
reviewing it is charged with constructive knowledge of its
contents. See Bokum v. Commissioner, 94 T.C. 126, 148 (1990),
affd. 992 F.2d 1132 (11th Cir. 1993). We must nonetheless
determine whether in signing the 1982 joint tax return petitioner
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