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On March 2, 2001, petitioner filed a petition with this
Court to dispute respondent’s denial of relief under section 6015
for taxable years 1982 through 1989.
OPINION
Generally, spouses filing a joint tax return are each fully
responsible for the accuracy of their return and for the full tax
liability. Sec. 6013(d)(3); Butler v. Commissioner, 114 T.C.
276, 282 (2000). Section 6015, however, provides various means
by which a spouse can be relieved of this joint and several
obligation. Petitioner makes her claim for such relief under
section 6015(b), (c), and (f). Except as otherwise provided in
section 6015, petitioner bears the burden of proof. Rule 142(a).
I. Jurisdiction
Our jurisdiction for taxable years 1982 to 1989 is dependent
on section 6015(e) because petitioner’s claim for relief was made
in a “stand alone” petition. Ewing v. Commissioner, 118 T.C.
494, 497 (2002). Respondent treated petitioner’s request for
relief under section 6015 as an election under section 6015(b),
(c), and (f). Further, petitioner timely filed her petition with
the Court for taxable years 1982 through 1988. We hold that we
have jurisdiction under section 6015(e) to review the denial of
petitioner’s request for relief under section 6015 for taxable
years 1982 through 1988.
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