Rhonda K. Juell, a.k.a. Rhonda K. Juell-Podlak, Petitioner, and Glenn M. Evans - Page 11




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               Petitioner claims that she is entitled to additional relief            
          from joint liability under section 6015(b), (c), and (f), beyond            
          the two-thirds relief already granted by respondent.                        
               A taxpayer spouse who meets certain qualifications may elect           
          relief under section 6015(b).  Generally, to qualify for relief             
          under section 6015(b)(1), the electing spouse must establish                
          that:                                                                       

                    (A) A joint return was filed;                                     
                    (B) there is an understatement of tax on the return               
               which is attributable to the erroneous items of the                    
               nonelecting spouse;                                                    
                    (C) in signing the return, the electing spouse did not            
               know, and had no reason to know, that there was such an                
               understatement;                                                        
                    (D) taking into account all the facts and                         
               circumstances, it is inequitable to hold the electing spouse           
               liable for the deficiency in tax for the taxable year                  
               attributable to the understatement; and                                
                    (E) a timely election has been made.                              

               Respondent does not dispute that petitioner meets the                  
          requirements of subparagraphs (A) and (E) of section 6015(b)(1),            
          but respondent contends that petitioner has not satisfied the               
          requirements of subparagraphs (B), (C), and (D).                            

          Section 6015(b)(1)(B):  Attributable to Nonelecting Spouse                  
               When determining whether an erroneous item is attributable             
          to a nonelecting spouse, we look not only to how ownership is               







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