- 8 - 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, inPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007