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redetermined deficiency continues to qualify as a substantial
understatement under section 6661(b)(1)(A).
III. Relief From Joint and Several Liability
Petitioner seeks relief from the joint and several liability
imposed by section 6013(d)(3). Section 6015(a) permits an
individual who has filed a joint return to elect to seek relief
from joint and several liability provided the taxpayer
meets the requirements of section 6015(b). The pertinent
requirements of section 6015(b) that must be met are as follows:
(A) a joint return has been made for a taxable year;
(B) on such return there is an understatement of tax
attributable to erroneous items of one individual
filing the joint return;
(C) the other individual filing the joint return
establishes that in signing the return he or she did
not know, and had no reason to know, that there was
such understatement; [and]
(D) taking into account all the facts and
circumstances, it is inequitable to hold the other
individual liable for the deficiency in tax for such
taxable year attributable to such understatement; * * *
An individual meeting the requirements of section 6015(b) is
relieved of liability for tax (including interest, penalties, and
other amounts) for the taxable year in question to the extent the
liability is attributable to the understatement described in
section 6015(b).
Respondent concedes that petitioner satisfies the first two
requirements but argues that she does not satisfy the last two:
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