Thornton, J., concurring: No relief is available under section 6015(c)(3)(C) if the Commissioner shows that the spouse seeking relief had “actual knowledge * * * of ‘any item giving rise to a deficiency (or portion thereof)”’. Majority op. p. 194. The majority opinion appropriately construes this statutory language to require, in the case of omitted income, “actual and clear awareness of the omitted in…
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