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excess of that already allowed.
Relying solely on an interpretation of respondent’s notice
of determination, petitioner argues on brief that she is entitled
to additional relief under section 6015(b). Her arguments are
confusing but appear to be as follows: (1) Respondent has
already determined in his notice of determination that petitioner
met all of the requirements for relief from joint and several
liability under section 6015(b) with respect to a portion of the
1985 and 1996 tax liabilities; (2) as a result, we should
interpret respondent’s notice of determination as granting
partial relief from the actual tax liability in the amounts
indicated, which would then reduce petitioner’s liability for the
additions to tax and interest proportionately; and (3) the notice
of determination does not state that it is only granting relief
from the additions to tax for fraud and related interest nor does
it mention section 6653(b). We reject petitioner’s arguments.
Although the notice of determination is ambiguous regarding the
nature of, and basis for, respondent’s determination that
petitioner is entitled to partial relief from joint and several
liability for the 1985 and 1986 assessments, the notice of
determination is clear that respondent granted petitioner partial
relief only. Regardless of how we interpret respondent’s notice
of determination, petitioner had an obligation to demonstrate
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