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the investment in the Hoyt partnerships. To the contrary, that
particular language simply associates the Hoyt partnerships with
the tax deficiencies and does not constitute an admission as to
the level of petitioner’s involvement in the Hoyt partnerships.
See Zaentz v. Commissioner, 90 T.C. 753, 762 (1988).
Because the understatements are attributable entirely to
Glenn, petitioner satisfies section 6015(b)(1)(B).
Section 6015(b)(1)(C): Know or Reason To Know2
A spouse seeking relief from joint liability under section
6015(b) must not have known or had reason to know at the time of
signing a joint tax return that there was an understatement of
tax on a return. Sec. 6015(b)(1)(C). In deduction cases, the
United States Court of Appeals for the Eighth Circuit has adopted
the standard set forth in Price v. Commissioner, 887 F.2d 959,
963-965 (9th Cir. 1989). See Erdahl v. Commissioner, 930 F.2d
585, 589 (8th Cir. 1991), revg. T.C. Memo. 1990-101.3
Under the Price standard, the Court inquires as to whether
“‘a reasonably prudent taxpayer under the circumstances of the
2“The requirement in sec. 6015(b)(1)(C) * * * is virtually
identical to the same requirement of former sec. 6013(e)(1)(C);
therefore, cases interpreting former sec. 6013(e) remain
instructive to our analysis.” Doyel v. Commissioner, T.C. Memo.
2004-35.
3Because an appeal in this case would lie in the U.S. Court
of Appeals for the Eighth Circuit, we follow Eighth Circuit law.
See Golsen v. Commissioner, 54 T.C. 742 (1970), affd. 445 F.2d
985 (10th Cir. 1971).
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