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court. Accordingly, the remaining issue is whether petitioner
had no actual knowledge of the income item leading to the
underpayment.
Based on our previous discussion of the facts and the
evidence presented in these cases, we believe that petitioner had
actual knowledge of all items of income received by the couple in
2001. Moreover, we again reiterate that petitioner did not deny
his knowledge of the items of unreported income at issue in these
cases.
As to the other items at issue, petitioner stated that he
had knowledge of the deductions claimed on the Schedule A, and
expenses reported on the Schedules C and E, as well as all
activity and accounts pertaining to World Works Diversified. The
majority of the deficiency at issue stems from respondent’s
denial of the expenses reported on Schedule C. Again, petitioner
testified that he knew about and believed in the veracity of all
items reported on the Schedule C for 2001 when he prepared it.
Therefore, because petitioner had actual knowledge of all of the
items that respondent disallowed and because he prepared the 2001
joint return at issue with this knowledge, we find that he is not
eligible for relief under section 6015(c).
Because petitioner is not eligible for relief under section
6015(b) and (c), we finally consider the equitable relief
provisions of section 6015(f). Section 6015(f) provides, in
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