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petitioner has a college degree, that she had full access to
joint bank accounts, that she balanced the couple’s checkbook,
that she knew of her status as a limited partner in the
partnership, and that she failed to discharge her duty of
inquiry, petitioner is deemed to have had reason to know of the
understatements on the income tax returns for the years at
issue.3 We conclude that petitioner does not qualify for relief
under section 6015(b).
Section 6015(c) allows a qualifying individual to receive
proportionate relief from joint and several liability for a
deficiency if, in addition to meeting other conditions, upon
electing relief under section 6015(c), the individual is divorced
or legally separated from the other spouse or has lived apart
from the other spouse for the past 12 months. Petitioner fails
to meet this requirement. She is still married to and living
with Golden. We conclude that petitioner does not qualify for
relief under section 6015(c).
Because we hold that petitioner is not entitled to either
full or proportionate relief under subsection (b) or (c) of
section 6015, we now consider whether she is entitled to
equitable relief. Under section 6015(f), the Commissioner may
grant equitable relief to an individual if relief is not
3 As to the fourth requirement of sec. 6015(b), petitioner
has not presented any evidence that it would be inequitable to
hold her liable for the deficiencies for the subject years.
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Last modified: November 10, 2007