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Therefore, the Court has no basis for limiting petitioner’s
liability to “50 percent” as she requests. This is especially
true in the light of the fact that petitioner does not qualify
for innocent spouse relief in her own right since she admits to
receiving and failing to report the items of income. Petitioner
does not qualify for relief under section 6015(b) because she
cannot establish that she did not know or had no reason to know
that there was an understatement of tax when she signed the
return. See sec. 6015(b)(1) and (2). Because the items giving
rise to the deficiency were directly allocable to petitioner,
section 6015(c) does not provide any avenue for relief. See also
sec. 1.6015-3(d)(2)(iii), Income Tax Regs. (stating that
erroneous items of income are allocated to the spouse who was the
source of the income). Finally, it is not inequitable to hold
petitioner liable for the deficiency since she fails one of the
threshold conditions for relief; i.e., “The income tax liability
from which the requesting spouse seeks relief is attributable to
an item of the * * * [other spouse]”. Rev. Proc. 2003-61, sec.
4.01(7), 2003-2 C.B. 296, 297; see also id. sec.
4.03(2)(a)(iii)(B), 2003-2 C.B. at 298 (stating that actual
knowledge of the item giving rise to the deficiency weighs
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