Nora Aranda - Page 5

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               Petitioner filed a timely petition with this Court under               
          section 6015(e) for review of respondent’s determination.  In her           
          petition, petitioner alleges:  (1) “Petitioner did not know and             
          had no reason to know that there was such an understatement”, and           
          (2) “It would be inequitable to hold Petitioner liable for the              
          deficiency, taking into account all the facts and circumstances.”           
          Petitioner requests abatement of all tax and additions to tax for           
          1985 and 1986 and a refund of amounts paid on the 1985 and 1986             
          assessments.                                                                
                                     Discussion                                       
               Generally, taxpayers filing a joint Federal income tax                 
          return are each responsible for the accuracy of their return and            
          are jointly and severally liable for the full tax liability.                
          Sec. 6013(d)(3).  However, in certain circumstances, a taxpayer             
          may obtain relief from joint and several liability under section            
          6015.                                                                       
               In this case, petitioner relies upon section 6015(b)(1)                
          which authorizes respondent to grant relief from joint and                  
          several liability if the taxpayer satisfies each requirement of             
          subparagraphs (A) through (E).  Section 6015(b)(1) 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;                                                     





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