| http://www.w3.org/ns/prov#value | - ment, and (iv) taking into account all facts and circumstances, it is inequitable to hold the other spouse liable for the deficiency in tax for such taxable year attributable to such substantial understatement, then the other spouse shall be relieved of liability for the tax, including interest, penalties and other amounts, for such taxable year to the extent such liability is attributable to such
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