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employed. I myself have no knowledge whatsoever of his
business dealings, in particular his stock transac-
tions. Further, I have never been involved in any of
his business dealings.
The only reason I signed the joint tax return in
the first place was because his accountant thought it
would be more convenient for him to file a joint re-
turn.
On September 10, 1999, in response to petitioner’s Form
8857, respondent’s Joint Compliance Branch sent petitioner a
letter (respondent’s September 10, 1999 letter to petitioner).
That letter stated in pertinent part:
Thank you for your request for Relief from Joint and
Several Liability (Form 8857) received March 26, 1999.
[X] Please complete the enclosed Form 886-A, Relief
from Joint and Several Liability Questionnaire.[1]
The additional information should be returned within 30
days from the date of this letter.
If you have any questions, you may write to us at the
address shown above, or you may call the above listed
number. This is not a toll-free number.
Thank you for your cooperation.
1The record does not contain a copy of the “Relief
from Joint and Several Liability Questionnaire” (ques-
tionnaire) to which respondent’s September 10, 1999
letter to petitioner referred.
Petitioner did not return a completed questionnaire to respon-
dent, nor did she otherwise respond to respondent’s September 10,
1999 letter to petitioner.
On September 10, 1999, respondent’s Joint Compliance Branch
also sent Mr. Mellen a letter (respondent’s September 10, 1999
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Last modified: May 25, 2011