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III. 1982 Through 1988 Tax Returns
Petitioner requests that the Court grant her relief from her
1982 through 1988 tax liabilities under section 6015(b), (c), or
(f). Petitioner contends that she relied on professionals to
prepare her tax return because the Federal tax laws are complex,
complicated, and confusing.
Respondent argues that petitioner is not entitled to relief
under section 6015(b), (c), or (f). Respondent contends that
petitioner failed to prove that she meets the requirements in
section 6015(b)(1)(B), (C), and (D). Further, respondent argues
that petitioner is not eligible for relief under section 6015(c)
because she is still married to Dr. Alt. Respondent also argues
that he did not abuse his discretion in denying relief under
section 6015(f) to petitioner because the factors in favor of not
granting relief under section 6015(f) outweigh the factors in
favor of granting relief to petitioner.
A. Relief Under Section 6015(b)
To qualify for relief from joint and several liability under
section 6015(b)(1), a taxpayer must establish that
(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 1 individual
filing the joint return;
(C) the other individual filing the joint return
establishes that in signing the return he or she did
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