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In support of her claim, Cyndie alleged that, at the time of
signing the joint income tax returns for the years in issue, she
did not know and had no reason to know of Phillip's
understatement of tax and that it would be inequitable to hold
her liable for deficiencies attributable to such understatements.
In the answer, respondent denied or denied for lack of sufficient
information Cyndie's factual allegations with respect to her
claim for relief under section 6015.
On March 15, 2000, respondent's counsel, the Associate
District Counsel, and the Appeals officer interviewed Cyndie for
the first time and evaluated her credibility concerning her
claim. Prior to this meeting, the parties had devoted most of
their discussions to the issue of the embezzlement income offset.
Cyndie did not supply any evidence to establish her qualification
for section 6015 relief until the meeting on March 15, 2000.
After the 2-hour interview, respondent concluded that Cyndie
qualified for section 6015 relief on all issues (not merely on
that of the embezzlement income) for all years in issue. The
parties' settlement, signed 5 days later, reflects respondent's
concession on the issue of section 6015 relief. Petitioners
assert that respondent belatedly conceded the merits of Cyndie's
position.
Section 6015(a) permits an individual who has filed a joint
return to elect to seek relief from joint and several liability
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