- 4 - Commissioner, 98 T.C. 383 (1992). Petitioner was a partner in the partnership that was the source of the unreported income in issue. Therefore, the Court has no basis for limiting petitioner’s liability to 50 percent as he requests. Petitioner does not qualify for section 6015 relief, because he admits to receiving and failing to report the items of income. Petitioner does not qualify for relief under section 6015(b), because he cannot establish that he did not know or had no reason to know that there was an understatement of tax when he signed the return. See sec. 6015(b)(1) and (2). Petitioner testified that he was unaware of the understatement on the return because he did not receive the form for 2003 reporting distributions from the partnership and he relied on his accountant to prepare the return. In view of his long-held interest in the partnership, however, he should have known that his income from the partnership was not included on the return and that an understatement would result. Because the items giving rise to the deficiency were directly allocable to petitioner, section 6015(c) does not provide any avenue for relief. See also sec. 1.6015-3(d)(2)(iii), Income Tax Regs. (stating that erroneous items of income are allocated to the spouse who was the source of the income). Finally, it is not inequitable to hold petitioner liable for the deficiency since he fails one of the thresholdPage: Previous 1 2 3 4 5 6 NextLast modified: March 27, 2008