Ranie M. Raymond - Page 8




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          sections explicitly require that a joint return be filed for                
          relief to be granted.6  Sec. 6015(b) and (c).                               

               6  Sec. 6015(b) provides:                                              
                    SEC. 6015(b).  Procedures for Relief from                         
               Liability Applicable to All Joint Filers.--                            
                         (1) In General.--Under procedures                            
                    prescribed by the Secretary, if--                                 
                              (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 not know, and had no reason                          
                         to know, that there was such an                              
                         understatement;                                              
                              (D) taking into account all                             
                         the facts and circumstances, it is                           
                         inequitable to hold the other                                
                         individual liable for the                                    
                         deficiency in tax for such taxable                           
                         year attributable to such                                    
                         understatement; and                                          
                              (E) the other individual                                
                         elects (in such form as the                                  
                         Secretary may prescribe) the                                 
                         benefits of this subsection not                              
                         later than the date which is 2                               
                         years after the date the Secretary                           
                         has begun collection activities                              
                         with respect to the individual                               
                         making the election,                                         
                    then the other person shall be relieved of                        
                                                             (continued...)           





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