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On August 10, 2000, respondent issued a Notice of
Determination Concerning Relief from Joint and Several Liability
Under Section 6015, determining that petitioner was not entitled
to relief under section 6015(f). On September 25 and October 30,
2000, petitioner filed a timely petition and an amended petition,
respectively, with the Court requesting relief for the years at
issue. Respondent notified Mr. August of the petitions.
OPINION
Petitioner requests that the Court grant her relief from
these taxes under section 6015(f).
Respondent argues that he did not abuse his discretion in
denying petitioner’s claim for relief under section 6015(f)
because petitioner presented no evidence supporting her claim,
and, therefore, petitioner did not qualify for relief under the
criteria provided in Rev. Proc. 2000-15, 2000-1 C.B. 447 (the
revenue procedure).
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 provides exceptions to this
general rule in certain circumstances. Butler v. Commissioner,
supra.
Section 6015(f) provides:
SEC. 6015(f). Equitable Relief.--Under procedures
prescribed by the Secretary, if--
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