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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 threshold
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