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B. Relief Under Section 6015(c)
We conclude that petitioner is not entitled to relief under
section 6015(c) for taxable years 1982 to 1988. At the time
petitioner filed her election for relief under section 6015,
petitioner and Dr. Alt were married, had not separated from one
another, and had remained members of the same household during
the 12-month period preceding the filing of the election by
petitioner.9 Sec. 6015(c)(3)(A)(i).10
C. Relief Under Section 6015(f)
Respondent argues that he did not abuse his discretion in
denying petitioner equitable relief under section 6015(f).11
9 We note that Dr. Alt was released from prison some time
earlier than 1995, and petitioner filed her election for relief
under sec. 6015 on Apr. 14, 2000.
10 Sec. 6015(c)(3)(A)(i) grants relief to individuals only
if:
(I) at the time such election is filed, such
individual is no longer married to, or is legally
separated from, the individual with whom such
individual filed the joint return to which the election
relates; or
(II) such individual was not a member of the same
household as the individual with whom such joint return
was filed at any time during the 12-month period ending
on the date such election is filed.
11 Sec. 6015(f) provides:
SEC. 6015(f). Equitable Relief.--Under procedures
prescribed by the Secretary, if--
(1) taking into account all the facts and
(continued...)
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