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petitioner's level of sophistication, we are convinced that
petitioner was well informed of the family's finances, that he
took part in everyday financial decisions, that he was aware of
all the distributions made from Ms. Chester's retirement account
during the year in issue (if not responsible for the decision to
withdraw the retirement funds), and, finally, that he was aware
of the failure to report such income on his joint return for the
year in issue.
Petitioner also contends that he did not sign the return for
the year in issue and that his signature must have been "forged".
However, we doubt the veracity of petitioner's claim in this
regard. On his submitted Form 8857, Request For Innocent Spouse
Relief, petitioner specifically admitted to having signed the
1996 return, declaring that "when I signed the joint return [for
1996] I did not know, and had no reason to know that there was a
substantial understatement of tax". In addition, petitioner
repeatedly admitted to having intended to file, and having in
fact filed, a joint return for the year in issue. Based on the
record, it is clear to us that petitioner did sign and file the
joint return for the year in issue.
Therefore, because petitioner does not meet at least one of
the requirements of section 6015(b) and (c), petitioner is not
entitled to relief from joint and several liability. See sec.
6015(b)(1)(C) and (c)(3)(C).
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