- 12 -
A –- at first she was going to sign it. And I
says, "What are you doin'? Why are you just signing that?
Hasn't that gotten you into trouble in the past?" And so
then she started to question it. And then he –- Billjanic
stated to her, "What do you care what is in the return?
It's going to make you not have to pay taxes for the rest of
your life. There's a big credit. Half of it's going to be
declared to you in the divorce decree, so just sign it." I
says, "What are the credits from? At least you could tell
us what the credits are from," and he would not tell us. He
says –- he says, "I really don't know. They're here. Sign
it. It benefits your mother. That's all there is to it."
On cross-examination, petitioner's daughter further testified:
Q You mentioned that you told your mom, when she
was going to sign the return –- * * * "Now, Mom, what are
you doing?" You know, "Hasn't this gotten you in enough
trouble in the past?"
A Right.
Q What were you talking about?
A Well, just from how badly that he treated her and
that he just expected her to do things. She never knew what
was going on. I felt that she succumbed to my father and
let him rule her and that she should be trying to
investigate, to read the documents, and to know what's going
on. I felt that she needed to understand what was going on
because much of her life she had been beaten down to the
point of where she didn't care what was going on and she
needed to learn this. She needed to be independent and read
the documents and understand them before she signed them.
As a general rule, spouses filing a joint return are each
jointly and severally liable for the full tax liability for the
taxable year of the return under section 6013(d)(3). Section
6015, however, provides several avenues for relief from the
imposition of joint and several liability on a spouse. Section
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