-6-
understatement of tax attributable to erroneous items of one
individual filing the joint tax return; (3) the spouse seeking
relief must establish that in signing the return he or she did
not know, nor have reason to know, that there was an
understatement of tax; and (4) taking into account all of the
facts and circumstances, it is inequitable to hold the requesting
spouse liable for the deficiency in tax for the taxable year
attributable to the understatement. The requesting spouse’s
failure to meet any one of these requirements prevents him or her
from qualifying for full or apportioned relief under section
6015(b). Alt v. Commissioner, supra at 313.
We focus on the third requirement concerning knowledge. The
facts indicate that Butler knew that there was an understatement
of tax when she signed her joint return. Butler admitted during
her testimony that she suspected that the claimed charitable
contributions were questionable and sensed that they were not
actually made by Schwendeman. She also admitted that she signed
the return with the inflated deductions because it was not worth
the effort to correct the reported amount. While Butler was
married to Schwendeman, she was aware of petitioners’ monthly
expenses and combined income. She also testified that she would
deal with the issue later, were it discovered that an inflated
amount was reported. We conclude that Butler fails the
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