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facts and circumstances, it is inequitable to hold the requesting
spouse liable for the deficiency in tax for the taxable year
attributable to the understatement. The requesting spouse’s
failure to meet any one of these requirements prevents him or her
from qualifying for full or apportioned relief under section
6015(b). Alt v. Commissioner, supra at 313.
Petitioner does not meet the second, third, or fourth
requirement for full or apportioned relief under section 6015(b).
The erroneous items, the losses from the partnership, are not
attributable solely to Golden. Petitioner admits that the
investment in the partnership was explained to her and that she
was aware of her status as a limited partner. She further admits
that she received the annual reports from the partnership listing
her losses, that Golden truthfully discussed the partnership with
her regularly, and that she willingly signed the tax returns for
the subject years without reviewing them. As to the latter
point, a reasonably prudent person in the position of petitioner,
a college-educated individual, would have reviewed each return
and at least inquired about the losses reported each year. As
this Court has previously stated in similar settings, a spouse
cannot escape tax responsibilities by ignoring the contents of a
tax return when signing it. See Mora v. Commissioner, 117 T.C.
279, 289 (2001); Albin v. Commissioner, T.C. Memo. 2004-230; see
also Levin v. Commissioner, T.C. Memo. 1987-7. Given that
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